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Practice Area: Treatises, Federal  Brand: WG&L

Federal Taxation of Partnerships and Partners  
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Federal Taxation of Partnerships and Partners, Fourth Edition, authored by three top expert practitioners in the field of partnership taxation and planning, is the internationally recognized and established leader for clear, accurate, and comprehensive analysis of the rules governing U.S. income taxation of transactions involving partners and partnerships.

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Federal Taxation of Partnerships and Partners has been cited as favorable and key authority by:

  • The federal courts in nearly 100 cases
  • The IRS in over 50 tax rulings
  • Congress in many committee reports

This Fourth Edition provides:

  • The most up-to-date, comprehensive coverage of the tax rules applicable to partnerships and their partners ( and to limited liability companies and their members)
  • Strategic advice on how to apply these rules to achieve the best tax results
  • In-depth explanations of the partnership tax rules along with sophisticated planning strategies, all organized in a transactional format that tracks the various stages of partnership activities through the partnership life cycle (formation, operations, mergers, and liquidations)
  • Numerous examples and illustrations that apply extremely complex tax rules to real life situations
  • Frequent supplementation that arms subscribers with the most current guidance and innovative strategies in the partnership tax area

Broad discussion is provided on the general partnership tax rules, along with insightful analysis of the most important and complex partnership tax topics, including:

  • Strategies affecting the formation of partnerships
  • Acquisition of partnership interests (or options to acquire such interests) in exchange for services or encumbered property
  • Transactions and planning involving the Section 752 partnership liability sharing rules
  • The validity of special allocations of partnership income/loss and the effect of partnership distributions and other transactions on capital accounts
  • Pitfalls and traps caused by the Section 704(c) contributed property provisions
  • Use of family limited partnerships in estate planning
  • Application of the partnership tax anti-abuse rule
  • The liquidation, merger, or division of partnerships and the treatment of retiring and surviving partners



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