835 Tax Memorandum 1 fall 2019.doc - Xiaomin Zhang F229C562 Tax Memorandum 1 Partnership Tax Year End Facts A client currently operates a business in a

835 Tax Memorandum 1 fall 2019.doc - Xiaomin Zhang F229C562...

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Xiaomin Zhang F229C562 Tax Memorandum 1 Partnership Tax Year End Facts A client currently operates a business in a U.S. corporation that is taxed according to Subchapter C of the Internal Revenue Code. The client consults the CPA firm at which you work about forming a partnership with two other business associates who also operate businesses in two separate U.S. C corporations. In the end, then, the partnership will have 3 partners, all of which are C corporations. The ownership percentages for each corporation in the partnership have not been determined. None of the three corporations have the same year-end, though the owners are open to changing year ends for their corporations, if necessary. The client is trying to decide what taxable year end can be used for the partnership entity. Issues The tax partner at your firm wants you to write a memorandum that summarizes the taxable year end rules and any restrictions placed on partners’ choices for partnership year ends. Include citations to at least one Internal Revenue Code section and at least one Regulation section.
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  • Spring '14
  • JeffreyJ.Bryant

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