This book tracks from formation to liquidation the life of a partnership or a limited liability company taxed as a partnership. Designed specifically for law students who have completed a basic individual income tax course, the casebook addresses the fundamental principles, Code and Regulation provisions, cases and administrative rulings governing taxation pursuant to Subchapter K. With the exception of the introduction, every chapter begins with a set of problems, a Code and Regulation assignment, a vocabulary list, and measurable learning objectives.

This book helps addresses the tax consequences of the most common transactions engaged in by limited liability corporations (LLCs)and partnerships. You will develop a level of comfort with the basic conceptual framework underlying partnership and LLC taxation, as well as gain an explanation of the tax consequences associated with issues most frequently confronted by tax practitioners. Topics covered include: basic tax structure of partnerships and LLCs; electing to be taxed as a partnership: "check-the-box" rules; tax consequences of partnership or LLC formation; partnership distributions; compensatory payments to partners; at-risk and passive activity limits; profit and loss allocations: general rules and restrictions; and reporting taxable income for partnerships and LLCs.

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.

Are you ready to master the advanced concepts of partnership taxation? Provide your clients with valuable advice and tax planning strategies and gain a working knowledge of the Internal Revenue Code's sophisticated partnership tax rules and regulations. This book takes a deep dive into the complexities of partnership tax law. It includes step-by-step examples to help guide you through the complicated world of advanced partnership and LLC tax law. Some of the many concepts covered in this course include special allocations, liquidating and non-liquidation distributions, property basis calculations under various scenarios, and sales of a partnership interest.

This book provides the simplest possible introduction of partnership taxation to students and beginning practitioners trying to understand the taxation of partnerships. Partnership taxation is an intricate body of law with the result that any "simplified" description of its rules would be so misleading as to be useless. We have therefore tried to make the subject accessible not by paraphrasing the rules, but by including over one hundred and forty examples of the rules that are as straightforward as possible. The text and examples focus on simple partnerships and limited liability companies that hold few assets and engage in routine transactions. The text places the rules in context by pointing out the purposes of the statute and regulations and presenting background information about practical matters such as how partnerships maintain capital accounts and how nonrecourse financing works. Using many examples, it then shows the operation of the rules in everyday cases encountered by practitioners. This is not a reference book: many interesting and difficult issues have been ignored. Some matters, such as the application of § 736 to noncash distributions and the taxation of tiered partnerships, are not discussed at all. Most of the points that are addressed, however, are discussed at considerable length. Our goal is to give students and beginning practitioners background material and illustrations so that they can begin to understand and work with a statute that was drafted for (and by) experienced practitioners and so that they can be prepared to make sense of the current law and any future changes. Most chapters end with a section comparing the tax treatment of partners with that of the shareholders of S corporations. Many students encountering partnership taxation for the first time have already studied subchapter S. We expect that an examination of some of the basic differences between subchapters S and K should help those students understand both subjects.