The Partnership Tax Practice Series includes more than 425 articles written by over 290 prominent partnership tax practitioners and delivers a sound analysis of cutting-edge transactional tax-related issues and innovative solutions for highly effective tax planning results. Laying a foundation with guidance on drafting and negotiating partnership and LLC agreements, The Partnership Tax Practice Series then examines more complex issues, including the tax treatment of private equity and hedge funds, debt workouts, and the latest guidance involving disguised sales  To provide a historical framework for today’s partnership tax practice, the series includes retrospectives on significant developments in partnership and real estate taxation, interesting partnership transactions of the past decade, and analysis of major decisions, including Hubert, Canal Corporation, G-I Holdings and Castle Harbour.

Major topics include:

• Basic calculation
• Allocation of partnership liabilities
• Partnership exit strategies
• Partnership mergers and divisions, including the anti-mixing bowl rules
• Tiered partnerships
• Taxation and use of real estate investment trusts (REITs)
• Dealing with LLC partnership equity compensation
• Partnerships in the public space
• COD income deferral guidance
• Tax shelters, the partnership anti-abuse rules, the economic substance doctrine and tax penalties
• International partnership and joint venture issues

Cliff Warren is Senior Counsel in the Passthroughs Group in the Office of Chief Counsel.  Prior to this, Cliff was head of tax at KKR and, before that, a large NYC hedge fund.  Cliff was also Tax Director of GE Capital Commercial Finance for about ten years.  He is a graduate of Middlebury College, New York Law School and the NYU tax program.