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Internal Revenue Service › Liquidation › Partnerships

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Trust Beneficiary Engages In Like Kind Exchange Using Trust Property

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It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more

Rivkin Radler LLP

Open Transaction Treatment for The Liquidation of a Partner’s Interest

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Another Mess- Congress has only a few days to avert a “shutdown” of the federal government. It’s not looking good in the House, as Speaker McCarthy has struggled to bring certain members of the majority into line, while...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

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At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Rivkin Radler LLP

Current Partnership Distributions: When Do You Figure Your Basis?

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Withdrawing Value- In general, the owners of a closely held business have several options by which they may withdraw money from the business without selling their interest in the business....more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

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Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

Farrell Fritz, P.C.

Liquidating A Partnership Interest? Beware The Effects Of Partnership Indebtedness

Farrell Fritz, P.C. on

Setting the Stage- Over the last couple of months, I’ve encountered several situations involving the liquidation of a partner’s interest in a partnership. Years before, the partnership had borrowed money from a third party...more

Lowndes

Status Update on Targeted Allocation Regulations

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I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more

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