gxpopppl.ppt - Partnership Operations Partnership Level Tax Determinations Partner Tax Consequences Loss Limitations Copyright 1998 1999 2000 2001 2002

gxpopppl.ppt - Partnership Operations Partnership Level Tax...

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Partnership Operations: Partnership Level Tax Determinations Partner Tax Consequences Loss Limitations © 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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Partnership Level Tax Determinations Partnership as deemed taxpayer computed as though individual §703(a)(1) certain deductions (eg §§151, 170, 212, 213) disallowed §703(a)(2) Holding period phenomenon Elections §703(b) Partnership taxable year Partnership method of accounting
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Partner Tax Consequences concept of “flow through” taxed to partners, not partnership §701 even if not distributed Note: P’shp can be liable as employer for employment based taxes, withholding, etc. preservation of character and other attributes partner-level determinations (limitations, etc) need for separate statement §702(a) reported on various return schedules special rules for certain “large” partnerships § § 771-777
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