Advanced Tax Strategies for LLCs and Partnerships

Larry Tunnell, Ph.D., CPA, is a professor in the accounting department at New Mexico State Univeristy.Robert Ricketts, Ph.D., CPA, is the Frank M. Burke Chair in Taxation, Department Head of Accounting at the Rawls College of Business, Texas Tech University. He has written numerous books on the taxation of partnerships and limited liability companies.

• Chapter 1 1-1Allocation of Partnership and LLC Income Under Section 704(b) 1-1Economic effect: The general test 1-3Deemed economic effect 1-12Alternate test for economic effect 1-13Substantiality 1-17Denied allocations: Determining the partners’ or LLC members’ interests in the entity 1-22Other issues 1-25Allocation of deductions attributable to nonrecourse debt 1-30Summary 1-35Chapter 2 2-1Allocations With Respect to Contributed Property: Section 704(c)(1)(A) 2-1The traditional method 2-4The traditional method with curative allocations 2-12The remedial allocations method 2-15Special rules 2-19Summary 2-22Chapter 3 3-1Allocation of Partnership Recourse Liabilities Under Section 752 3-1How liabilities affect partner tax consequences 3-2Allocation of liabilities among the partners: In general 3-12Allocation of recourse liabilities 3-15Chapter 4 4-1Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b) 4-1Distinguishing between recourse and nonrecourse liabilities 4-2Allocation of nonrecourse debts 4-7Treatment of contingent liabilities 4-15Chapter 5 5-1Advanced Distribution Rules 5-1Non-liquidating distributions generally 5-2Distribution of multiple properties 5-7Summary 5-18Chapter 6 6-1Adjustments to the Basis of Partnership or LLC Assets 6-1Section 743: Adjustments following the transfer of a partnership interest 6-3Distributions of partnership property 6-6Allocating the adjustment amount among partnership properties 6-15Chapter 7 7-1Sale of an Interest in a Partnership or LLC 7-1General tax consequences associated with sale 7-2“Hot” assets and Section 751(a) 7-7Collectibles and unrecaptured Section 1250 gain 7-12Installment sales 7-14Net investment income tax 7-16Sale of an active (non-passive) interest in a partnership or LLC 7-17Sale of a passive interest in a partnership or LLC 7-19Purchaser of a partnership interest 7-20Glossary Glossary 1Index Index 1Solutions Solutions 1Chapter 1 Solutions 1Chapter 2 Solutions 3Chapter 3 Solutions 4Chapter 4 Solutions 6Chapter 5 Solutions 8Chapter 6 Solutions 10Chapter 7 Solutions 12