TABLE OF CONTENTS

• Chapter 1, Initial Year Return Issues
  • INTRODUCTION
  • This chapter deals with three specific types of expenses:
  • Organizational Expenses
  • Syndication Expenses
  • Start Up Expenses.
  • Other issues covered in this chapter include the tax implications of payments made to partners:
  • IRC section 707(a) - Partner or Non-Partner
  • Receipt of a Capital or Profits Interest
  • Payments Capitalized, Deducted, or Distributed?
  • Guaranteed Payments
• Chapter 2, Capital Accounts, Basis, and Liabilities
  • INTRODUCTION
  • Capital accounts
  • Partner's basis in his or her partnership interest
  • Partnership's basis in its assets
  • Contributions to the Partnership
  • Partnership liabilities
  • Accounting for Book/Tax differences
  • IRC section 754 election
• Chapter 3, Contributions of Property with Built-in Gain or Loss IRC section 704(c)
  • INTRODUCTION
  • IRC section 704(c) in the context of non-depreciable property
  • IRC section 704(c) in the context or depreciable property IRC section 704(c) in the context of amortizable property
  • Impact of IRC section 704(c) on the sharing of non-recourse liabilities
  • The Anti-Abuse Rule
  • -Reverse" IRC section 704(c) which addresses re-valuations
• Chapter 4, Distributions
  • Basics - Current and Liquidating Distributions
  • Disguised Sales
  • Distributions of Built-in Gain or Loss Property to a Noncontributing Partner
  • Distributions of Property to a Partner that Contributed Built-in Gain or Loss Property
  • Disproportionate Distributions
• Chapter 5, Loss Limitations
• Chapter 6, Partnership Allocations
  • INTRODUCTION
  • Factors considered in determining the partners' interests in the partnership
  • Economic effect
  • Substantiality
  • Allocation of items attributable to non-recourse debt
  • Allocation of tax credits
• Chapter 7 Dispositions of Partnership Interest
  • INTRODUCTION
  • A partner can dispose of a partnership interest in the following ways:
  • By sale to one or more of the other partners.
  • By sale to a third party.
  • By exchange of the partnership interest for other property.
  • By transfer back to the partnership in return for at least one liquidating distribution leading to a complete liquidation of the partnership interest.
  • By retirement.
  • By gift or contribution.
  • By death.
  • By surrendering the partnership interest through abandonment, forfeiture, or worthlessness of the partnership interest. Each of the above methods for disposing of a partnership interest is covered in this chapter.
  • This chapter also addresses:
  • The character of the gain or loss on the disposition of a partnership interest.
  • The effect of related debt disposition.
  • The recognition of accumulated suspended passive losses associated with a partnership interest.
• Chapter 8 Real Estate Issues in Partnerships
  • INTRODUCTION
  • Approximately 50 percent of all partnerships are involved in the real estate business. A partnership may be involved in real estate development, construction, or leasing. Even though a partnership may not be involved in a real estate business it may own or lease real estate. This chapter covers various tax issues related to real estate such as:
  • Cancellation of Indebtedness
  • Tufts/ Non-recourse Debt and Unpaid Interest
  • Accrued Contingent Interest
  • Bankruptcy
  • Low Income Housing Tax Credit
  • Zombie Partnerships
  • Uniform Capitalization - IRC section 263A
• Chapter 9, Tax Shelters
  • INTRODUCTION -- This chapter covers:
  • Corporate Tax Shelter Characteristics
  • Office of Tax Shelter Analysis
  • Tax Shelter Disclosure
  • Partnership Anti-Abuse Regulations
  • Sham Partnership/Sham Partners
  • Judicial Doctrines
• Chapter 10 International (Reserved)
• Chapter 11, Family Partnerships
• Chapter 12, Syndicated Investment Partnerships
• Chapter 13 TEFRA GLOSSARY