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161 (Issue Date February 20, 2008) [As Amended] [Full Text] [Status] FSP FAS 140-4 and FIN 46(R)-8—Disclosures by Public Entities (Enterprises) about Transfers of Financial Assets and Interests in Variable Interest Entities (Issue Date June 8, 2005) [Full Text] [Status] FSP FAS 144-1—Determination of Cost Basis for Foreclosed Assets under FASB Statement No.15 and the Measurement of Cumulative Losses Previously Recognized under Paragraph 37 of FASB Statement No.As with all other aspects of partnership taxation, the dual nature of a partnership for tax purposes — as at times an aggregation of its partners, and at times an entity — complicates the discussion, particularly, because no one, including the author, has been able to articulate a comprehensive statement of when the aggregate, and when the entity, aspect should predominate. Transfer to Controlled Corporation, or in Reorganization e. Section 754 Election (1) Successor's Basis Adjustment under § 754 (2) Basis Adjustment Without § 754 Election - § 732(d) b. Further complication arises because the “tax” partnership includes not only entities organized as general or limited partnerships under state law, but also the newer forms of limited liability partnerships, primarily for professionals, and the, increasingly popular, limited liability company. Tiered Partnerships (1) Transfer to Upper-Tier Partnership (2) Distribution by Upper-Tier Partnership (3) Mixing Bowl Transactions (a) Contributed Property Distributed to Another Partner (b) Other Property Distributed to Contributing Partner f. Valuing Deceased Partner's Interest (1) Buy-Sell Agreements (2) Valuation Discounts and Premiums c. M., Partnerships — Current and Liquidating Distributions; Death or Retirement of a Partner); abandonment of the interest; nonrecognition transfers, including the special issues for the successor to a deceased partner; the possible termination of the partnership as a result of sales and exchanges of partnership interests, tax allocations for the year of sale; and suspended losses of transferor partners. Part III deals with taxable sales and other dispositions of the partnership business and assets, including mergers, incorporations and changes in form. M., Partnerships — Formation and Contributions of Property or Services. Disposition of Partnership Interests; Partnership Termination Introductory Material A. 5, 57, and 107 and rescission of FASB Interpretation No. 16 and 17 When a Savings and Loan Association or a Similar Institution is Acquired in a Business Combination Accounted for by the Purchase Method—an interpretation of APB Opinions No.16 and 17 (Issue Date May 9, 2008) [Full Text] [Status] FSP APB 18-1—Accounting by an Investor for Its Proportionate Share of Accumulated Other Comprehensive Income of an Investee Accounted for under the Equity Method in Accordance with APB Opinion No.
Unincorporated Entity to Corporation Working Papers Table of Worksheets Worksheet 1 Disguised Sale Disclosure Statement for Liquidating Distribution (Former Prop. § § 1.707-7(k) and -8(b)(1)) Worksheet 2 Election to Adjust Basis of Partnership Property Under § 754 (Regs. The discussion in this Portfolio involves not only analyzing the relevant statutory and regulatory materials, but also the large body of case law, revenue rulings, and other IRS pronouncements, including technical advice memoranda and private letter rulings, that are all part of this, unfortunately complex, body of tax law. After a brief Introduction in Part I, Part II discusses the consequences for the transferor, the transferee, and the partnership (the continuing partners) from sales, including disguised sales, of partnership interests, including distinguishing sales from withdrawals (which are considered in detail in 716 T. Transfer of Partnership Interests (Interests-Up) d. § 1.754-1(c)) Worksheet 4 Preamble to REG-149519-03, Former Proposed Regulations on § 707 Regarding Disguised Sales, 69 Fed.
Allocating Price - § 1060 (1) Amount Allocated (2) Residual Method (3) Amortization of Intangibles by Purchaser - § 197 b.