Chapter 1 1-1
Overview: Basic Tax Structure of Partnerships and LLCs 1-1
What is a partnership for federal income tax purposes? 1-2
Partnerships versus other entities 1-3
Electing to be taxed as a partnership: The “check-the-box” rules 1-11
Overview of the basic framework of partnership taxation 1-14
Partnership operations 1-16
Chapter 2 2-1
Tax Consequences of Partnership or LLC Formation 2-1
Determination of basis 2-2
Effect of entity operations 2-3
Effect of liabilities 2-4
Partnership interests obtained for services 2-11
Transfer of a capital interest 2-13
Transfer of a profits interest 2-17
Campbell 2-20
Lessons for tax advisers 2-22
Chapter 3 3-1
Partnership Distributions 3-1
Introduction 3-2
Liquidating distributions: Proportionate 3-11
Sale of distributed property 3-15
Section 736: Death or retirement of a partner from professional services partnerships or LLCs 3-16
Chapter 4 4-1
Compensatory Payments to Partners 4-1
Introduction 4-2
Self-employment income of partners 4-15
Proposed regulations concerning limited partners’ self-employment income 4-17
Chapter 5 5-1
At-Risk and Passive Activity Limits 5-1
Overview 5-2
Basis and at-risk limitations 5-7
Gross income from passive activities 5-14
Passive activity deductions 5-17
Who is subject to the passive loss limitations? 5-18
What are passive activities? 5-19
Rules of application 5-29
Grouping activities 5-34
Chapter 6 6-1
Overview of Profit and Loss Allocations: General Rules and Restrictions 6-1
Introduction 6-2
Section 704(b): Allocations must have “substantial economic effect” 6-3
Allocations with respect to contributed property: Section 704(c)(1)(A) 6-15
Chapter 7 7-1
Reporting Taxable Income for Partnerships and LLCs 7-1
Overview: Partnership tax return 7-2
General tax payment and reporting scheme 7-9
Form 1065: Income 7-14
Form 1065: Expenses 7-18
Schedules K and K-1 7-26
Interpreting Schedule K-1 7-38
Appendix A A-1
Sample Partnership Tax Return A-1
Facts and financial data A-3
Glossary Glossary 1
Index Index 1
Solutions Solutions 1
Chapter 1 Solutions 1
Chapter 2 Solutions 3
Chapter 3 Solutions 4
Chapter 4 Solutions 5
Chapter 5 Solutions 7
Chapter 6 Solutions 8
Chapter 7 Solutions 10