gxpoverv.ppt - Partnership Taxation Overview Copyright 1998...

Partnership Taxation:
Overview
© Copyright 1998, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009 James Edward Maule
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Favorable timing, including nonrecognition treatment
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Favorable characterization (CG, OL)
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Advantageous allocations
1. Planning objectives
2. The challenges of partnership taxation
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Concept: aggregate v entity
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Dual focus: tax shelters v. business partnerships
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Parallel tracks: partnerships v. larger partnerships
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Circularity of interrelationships
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Multiple items to keep track of (e.g.:)
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partner adjusted basis in partnership interest
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partnership adjusted basis in assets
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capital accounts
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basis adjustments
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Complexity [next slide]

Complexity
(1) computational complexity
(e.g., impact of OI and CG rate differences, basis
adjustments, basis allocation,)
(2) compliance complexity
(e.g., record-keeping, basis v. capital account)
(3) technical complexity
(e.g., poor drafting, poor organization, volume,