U.S. Taxation of Partnerships: Advanced Topics

As the number of businesses registered as partnerships continues to grow in the United States (U.S.)—there are now more than seven million—it is imperative for parties with business interests in the country to be fully informed of the challenges pertaining to this sui generis form of business and its intricate body of tax law. In an illustrative manner not covered by other books on the subject, this invaluable guide discusses, analyzes, dissects, and helps resolve issues arising in such contexts as accounting methods, anti-abuse rules, liabilities, dissolutions, mergers, and bankruptcy, with expert guidance on preparing partnership financial statements. With numerous boxed examples and references to important court cases, the author thoroughly describes such topics as the following: - types of partnerships (LP, LLP, LLC, PTP);
- the two concepts of partnerships;
- partnership formation;
- transactions between partnership and partners;
- allocation of revenues among partners;
- the partnership taxable year;
- base erosion and anti-abuse tax (BEAT);
- centralized partnership audit regime;
- recourse and nonrecourse liabilities; and
- special tax rules for publicly traded partnerships (PTPs).
Key abstract concepts are explained in a down-to-earth way, and all formal requirements—filing the partnership tax return (Form 1065), reporting, preparing for an audit, and so on—are clearly illustrated with examples. As the first book to describe the economics of partnerships in a concise and comprehensive manner, this book provides a reliable and authoritative overview of the complexities of U.S. partnership taxation and expounds the relevant rules in accessible language. It will be warmly welcomed by tax law practitioners, members of international and U.S. tax law associations, tax academics, and the international business communities with interests in the U.S.