gxpoverv.ppt - Partnership Taxation Overview Copyright 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 James Edward Maule Applicable to all

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

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Partnership Taxation: Overview © Copyright 1998, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009 James Edward Maule Applicable to all slides in set Unauthorized copying, distribution, or use of these slides is a violation of the Academic Rules of the Villanova Graduate Tax Program.
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Favorable timing, including nonrecognition treatment Favorable characterization (CG, OL) Advantageous allocations 1. Planning objectives 2. The challenges of partnership taxation Concept: aggregate v entity Dual focus: tax shelters v. business partnerships Parallel tracks: partnerships v. larger partnerships Circularity of interrelationships Multiple items to keep track of (e.g.:) partner adjusted basis in partnership interest partnership adjusted basis in assets capital accounts basis adjustments Complexity [next slide]
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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,
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  • Spring '14
  • JamesE.Maule
  • Balance Sheet, Partnership taxation, comp TI/sep stat, partnership adjusted basis

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