Treatment of liquidating forces dating
Liquidating distributions may be accompanied by other retirement payments that do not represent consideration for the withdrawing partner's interest in partnership property, and may be deferred compensation, or other claims against past or future partnership income. Distribution of Property Subject to a 743(b) Basis Adjustment D.
102–486)] Worksheet 6 Omnibus Budget Reconciliation Act of 1993 Conference Report Section 13262 - Modify Special Treatment of Certain Liquidation Payments (P. Distributions, usually liquidating distributions, are important components of major partnership restructurings, including divisions, mergers, incorporations, and changes in legal form. Transfers After December 14, 1999 (1) Allocations Between Asset Classes (2) Allocations Within Asset Classes (3) Increases (4) Decreases (5) Special Rule for Stock of Corporate Partners: 755(c) (6) Requirement that Difference Between Value and Basis Be Reduced b. Timing of Basis Adjustments Caused by Liquidation of Partner's Interest 4. 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. Elliott Manning, AB (with honors) Columbia College (1955), JD m.c.l., Harvard Law School (1958). M., Partnerships—Disposition of Partnership Interests or Partnership Business; Partnership Termination; Choosing the Business Entity (Little Brown 1995); and Corporate Buy-Sell Agreements (Little Brown 1995). General Rules Applicable to Partnership Distributions B. Subsequent Sales of Distributed Property Introductory Material A.