" ... analyzes in depth the U.S. federal income taxation of publicly traded partnerships and their partners"--Portfolio description.

In general, business entities are subject to the section 11 corporate tax if they are publicly traded. Corporate tax is justified under the rationale that entities will pay tax in exchange for access to an established market because liquidity has value. It allows owners of large enterprises to easily exit by selling their shares. Publicly traded partnerships can avoid being subject to corporate tax under current law if they earn primarily qualifying income. The best rationale for this exemption from corporate tax is that the partners could have access to the income of the publicly traded partnership by buying the assets of the partnership directly. Congress should redefine qualifying income to make the definition better fit that rationale by classifying income as qualifying only if it is earned by holding publicly traded stock or other publicly traded assets.

As the number of businesses registered as partnerships continues to grow in the United States (U.S.)—there are now more than seven million—it is imperative for parties with business interests in the country to be fully informed of the challenges pertaining to this sui generis form of business and its intricate body of tax law. In an illustrative manner not covered by other books on the subject, this invaluable guide discusses, analyzes, dissects, and helps resolve issues arising in such contexts as accounting methods, anti-abuse rules, liabilities, dissolutions, mergers, and bankruptcy, with expert guidance on preparing partnership financial statements. With numerous boxed examples and references to important court cases, the author thoroughly describes such topics as the following: types of partnerships (LP, LLP, LLC, PTP); the two concepts of partnerships; partnership formation; transactions between partnership and partners; allocation of revenues among partners; the partnership taxable year; base erosion and anti-abuse tax (BEAT); centralized partnership audit regime; recourse and nonrecourse liabilities; and special tax rules for publicly traded partnerships (PTPs). Key abstract concepts are explained in a down-to-earth way, and all formal requirements—filing the partnership tax return (Form 1065), reporting, preparing for an audit, and so on—are clearly illustrated with examples. As the first book to describe the economics of partnerships in a concise and comprehensive manner, this book provides a reliable and authoritative overview of the complexities of U.S. partnership taxation and expounds the relevant rules in accessible language. It will be warmly welcomed by tax law practitioners, members of international and U.S. tax law associations, tax academics, and the international business communities with interests in the U.S.