Table of Contents
Chapter 1 1-1 Allocation of Partnership and LLC Income Under Section 704(b) 1-1
Economic effect: The general test 1-3
Deemed economic effect 1-12
Alternate test for economic effect 1-13
Substantiality 1-17
Denied allocations: Determining the partners’ or LLC members’ interests in the entity 1-22
Other issues 1-25
Allocation of deductions attributable to nonrecourse debt 1-30
Summary 1-35
Chapter 2 2-1
Allocations With Respect to Contributed Property: Section 704(c)(1)(A) 2-1
The traditional method 2-4
The traditional method with curative allocations 2-12
The remedial allocations method 2-15
Special rules 2-19
Summary 2-22
Chapter 3 3-1
Allocation of Partnership Recourse Liabilities Under Section 752 3-1
How liabilities affect partner tax consequences 3-2
Allocation of liabilities among the partners: In general 3-12
Allocation of recourse liabilities 3-15
Chapter 4 4-1
Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b) 4-1
Distinguishing between recourse and nonrecourse liabilities 4-2
Allocation of nonrecourse debts 4-7
Treatment of contingent liabilities 4-15
Chapter 5 5-1
Advanced Distribution Rules 5-1
Non-liquidating distributions generally 5-2
Distribution of multiple properties 5-7
Summary 5-18
Chapter 6 6-1
Adjustments to the Basis of Partnership or LLC Assets 6-1
Section 743: Adjustments following the transfer of a partnership interest 6-3
Distributions of partnership property 6-6
Allocating the adjustment amount among partnership properties 6-15
Chapter 7 7-1
Sale of an Interest in a Partnership or LLC 7-1
General tax consequences associated with sale 7-2
“Hot” assets and Section 751(a) 7-7
Collectibles and unrecaptured Section 1250 gain 7-12
Installment sales 7-14
Net investment income tax 7-16
Sale of an active (non-passive) interest in a partnership or LLC 7-17
Sale of a passive interest in a partnership or LLC 7-19
Purchaser of a partnership interest 7-20
Glossary Glossary 1
Index Index 1
Solutions Solutions 1
Chapter 1 Solutions 1
Chapter 2 Solutions 3
Chapter 3 Solutions 4
Chapter 4 Solutions 6
Chapter 5 Solutions 8
Chapter 6 Solutions 10
Chapter 7 Solutions 12
