The Partnership Tax Practice Series (2010 Edition)
Front Matter
Table of Contents
Chapter 1. The Partnership Union: Opportunities for Joint Ventures and Divestitures
Chapter 2. Partnership Joint Ventures of Operating Business
Chapter 3. Final Section 197 Regulations: Application to Partnership Transactions
Chapter 4. Section 197 and Partnership Transactions
Chapter 5. Fifteen Years of Anti-Churning: It’s Time to Make Butter
Chapter 6. Adding a New Cash Partner to an Operating Partnership
Chapter 7. Dealing with the Contribution of Property to a Partnership
Chapter 8. Musings on Partnership Contributions
Chapter 9. Cash and Carried Interests: Protecting the Investor and the Developer in a Real Estate Partnership
Chapter 10. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 11. Several Comments on Drafting Partnership and LLC Agreements
Chapter 12. Significant Developments in Partnership Taxation 2003-2004
Chapter 13. Significant Developments in Partnership Taxation 2004-2005
Chapter 14. Significant Developments in Partnership Taxation 2006-2007
Chapter 15. Significant Developments in Partnership Taxation 2007-2008
Chapter 16. Significant Developments in Partnership Taxation 2008-2009
Chapter 17. Getting Down to Business: Partnerships and Miscellaneous Itemized Deductions
Chapter 18. Selected Partnership Case Studies
Chapter 19. Selected Partnership Case Studies (PowerPoint Slides)
Chapter 20. Interesting Partnership Transactions of 2005
Chapter 21. Interesting Partnership Transactions of 2006
Chapter 22. Interesting Partnership Transactions of 2007
Chapter 23. Interesting Partnership Transactions of 2008
Chapter 24. Interesting Partnership Transactions of 2009
Chapter 25. Opening Pandora’s Box: Who is (or Should Be) a Partner?
Chapter 26. Alliances Not in Partnership or Corporate Form
Chapter 27. When is a Partner Not a Partner?
Chapter 28. The Uncertain Certainty of Being a Partner: Classification as a Partner for Tax Purposes
Chapter 29. A History and Analysis of the Co-Ownership-Partnership Question
Chapter 30. A Catalogue of Legal Authority Addressing the Federal Definition of Tax Partnership
Chapter 31. Rev. Proc. 2001-43, Section 83(b), and Unvested Profits Interests—The Final Facet of Diamond?
Chapter 32. Compensating the Service Partner with Partnership Equity: Code §83 and Other Issues
Chapter 33. Partnership Interests for Services
Chapter 34. A Layman’s Guide to LLC Incentive Compensation
Chapter 35. Proposed Regulations on Partnership Interests Issued for Services: Practical Problems and Opportunities
Chapter 36. Prop. Regs. on Partnership Equity for Services: The Collision of Section 83 and Subchapter K
Chapter 37. Proposed Partnership Equity Compensation Regulations: “Little or No Chance” of Satisfying Everyone
Chapter 38. Proposed Regulations on Partnership Equity for Services Illustrative Examples
Chapter 39. First IRS Ruling on Unvested Partnership Profits Interests: No Income Recognized but Questions Remain
Chapter 40. Cover Letter Dated January 23, 2004 from Andrew N. Berg to the Honorable Pamela F. Olson and the Honorable Mark W. Everson Enclosing New York State Bar Association Tax Section’s Report No. 1049 on the Taxation of Partnership Interests Received for Services and Compensatory Partnership Options
Chapter 41. Recent Developments in Compensating Employees: Partnerships, Corporations, and Going Public
Chapter 42. Partners and the SECA Tax
Chapter 43. Selected Tax Issues in Equity-Based Compensation for Partnerships and LLCs
Chapter 44. Tax Legislation: CRS Report, ‘Taxation of Hedge Fund and Private Equity Managers’
Chapter 45. Tax Legislation: CRS Report, ‘Taxation of Private Equity and Hedge Fund Partnerships: Characterization of Carried Interest’
Chapter 46. Taxation of Carried Interests
Chapter 47. Partnership Deferred Compensation and Carried Interests
Chapter 48. Taxing Partnership Profits Interests as Compensation Income
Chapter 49. Taxation of Service-Connected Property Transfers Under Code Section 83
Chapter 50. A Pragmatic Case for Taxing an Equity Fund Manager’s Profit Share as Compensation
Chapter 51. Tax Planning for Partnership Options and Compensatory Equity Interests
Chapter 52. Partnership Use of Corporate Partner Stock and Options as Compensation Easier Under the 1032 Regs
Chapter 53. Section 83(b), Section 409A, Section 457A, and Subchapter K
Chapter 54. Employee Benefits Considerations in Joint Ventures
Chapter 55. Tax Issues Raised by Partnership Options
Chapter 56. Noncompensatory Partnerships Options: The Proposed Regulations
Chapter 57. Cover Letter Dated January 23, 2004 from Andrew N. Berg to the Honorable Pamela F. Olson and the Honorable Mark W. Everson Enclosing New York State Bar Association Tax Section’s Report No. 1048 on Proposed Regulations Relating to Partnership Options and Convertible Securities
Chapter 58. Partnership Basis Issues Including Allocating Liabilities Among Partners
Chapter 59. Partnership Interest Basis Issues
Chapter 60. Planning Partnership Admissions and Book-Ups
Chapter 61. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 62. Allocating Partnership Liabilities Under Section 752 (PowerPoint Slides)
Chapter 63. Allocating Partnership Liabilities
Chapter 64. Reverse Allocations: More Than Meets the Eye
Chapter 65. Guarantees, DROs, and CCOs: Getting Partnership Liability Allocations Right
Chapter 66. Several Thoughts on Drafting Target Allocation Provisions
Chapter 67. Target Allocations: The Swiss Army Knife of Drafting (Good for Most Situations—But Don’t Bet Your Life on It)
Chapter 68. Economic Risk of Loss: The Devil We Think We Know
Chapter 69. Simple Distributions from Leveraged Partnerships
Chapter 70. The Impact of Disregarded Entities on Partnership Liability Allocations: Proposed Regulations Under I.R.C. Section 752
Chapter 71. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 72. Partnership Assumption of Partnership “Liabilities”—Proposed Regulations
Chapter 73. New Partnership Liability Regulations Target Abuse but Sweep More Broadly
Chapter 74. Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 75. Section 752(c): A Riddle Wrapped in a Mystery Inside an Enigma
Chapter 76. Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint Slides)
Chapter 77. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 78. The Alternate Test for Economic Effect and the Qualified Income Offset
Chapter 79. Drafting Partnership Agreements for Substantial Economic Effect (PowerPoint Slides)
Chapter 80. Some Nuances of Partnership Nonrecourse Deductions
Chapter 81. Hedge Fund Stuffing Allocations: A Path Through the Maze
Chapter 82. Section 704(b)—Substantiality
Chapter 83. Ruminations on Substantiality Under the Section 704(b) Regulations
Chapter 84. Rev. Rul. 99-43: When to Hold’em, When to Fold’em, And When to Book-Down
Chapter 85. A Partner’s Interest in the Partnership for Purposes of Section 704(b)
Chapter 86. Identifying Partners’ Interest in Profits and Capital: Uncertainties, Opportunities and Traps
Chapter 87. FAQ-Filled Guidance on Computing a Partner’s Interest In Profits, Losses, and Capital—Part 1
Chapter 88. FAQ-Filled Guidance on Computing a Partner’s Interest in Profits, Losses, and Capital—Part 2
Chapter 89. In Search of Partners’ Interests in the Partnership: The Alternative to Substantial Economic Effect
Chapter 90. Partners’ Varying Interests Under Proposed Regulations
Chapter 91. Some Nuances of the Minimum Gain Chargeback
Chapter 92. Tax Aspects of Partnership Dilution Provisions
Chapter 93. Planning Under the Often Overlooked At-Risk Rules, Including the Impact of the Hubert Case
Chapter 94. The Impact of a Capital Account Deficit Restoration Obligation on a Partner’s At-Risk Amount and Share of Liabilities: Hubert Enterprises, Inc. v. Commissioner
Chapter 95. Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case
Chapter 96. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 97. Passive Losses, LLCs and LLPs—Two Courts Reject the Service’s Attempt to Limit Losses
Chapter 98. Treatment of LLCs Under the Passive Loss Rules—Getting it Straight
Chapter 99. A Primer on Allocations with Respect to Contributed and Revalued Property Section 704(c)
Chapter 100. The Section 704(c)(1)(A) Regulations
Chapter 101. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 102. Planning Opportunities Remain Under the Final Partnership Allocation Rules for Contributed Property
Chapter 103. Section 704(c) and the Regulations Thereunder
Chapter 104. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 105. Making Section 704(c) Sing for You
Chapter 106. Section 704(c) and Related Issues
Chapter 107. Complex Section 704(c) Issues Arising In The Execution Of Partnership Transactions (PowerPoint Slides)
Chapter 108. A Response to Notice 2009-70
Chapter 109. Notice 2009-70: A Focus on Complex Section 704(c) Netting Versus Layering Issues
Chapter 110. Revaluations Revisited: Partnership Allocations and the Demise of the Ceiling Rule
Chapter 111. Extracting Equity on a Tax-Free Basis (PowerPoint Slides)
Chapter 112. Partnership Disguised Sale Rules
Chapter 113. Disguised Sales Revisited
Chapter 114. Liabilities Under the Disguised Sale Rules of Section 707
Chapter 115. An Analysis of the Rules Governing Disguised Sales to Partnerships: Section 707(a)(2)(B)
Chapter 116. New Proposed Regulations on Disguised Sales of Partnership Interests
Chapter 117. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 118. The Section 704(c)(1)(B) Final Regulations
Chapter 119. Final Regulations Under Sections 704(c)(1)(B), 737 and 731(c)
Chapter 120. The Section 737 Regulations
Chapter 121. Partnership Mixing-Bowl Issues (PowerPoint Slides)
Chapter 122. Creative Partnership Exit Strategies
Chapter 123. Partnership Exit Strategies and the Failure of the Substantiality Test
Chapter 124. Deceptive Simplicity: Continuing and Current Issues with Guaranteed Payments
Chapter 125. Sales of Partnership Interests
Chapter 126. Selling Your Partnership Business?—You Have Two Choices with Different Tax Consequences
Chapter 127. State Income Tax Treatment of Dispositions of Interests in Flow-Through Entities and Joint Ventures
Chapter 128. Partnerships and Ordinary Income
Chapter 129. Partnership Sales, Exchanges, Dispositions, Distributions & Terminations—2003
Chapter 130. Partnership Conversions: Making Something Out of Nothing
Chapter 131. Partnership Distributions of Marketable Securities
Chapter 132. Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 133. A Comprehensive Guide to Partnership Terminations, Including the New Proposed Regulations
Chapter 134. Planning with and Around the Partnership Termination Rules
Chapter 135. Planning for Partnership Distributions with Respect to Redemptions, Withdrawals, Retirements, Dismissals, Expulsions, Terminations, Liquidations, and Deaths of Partners
Chapter 136. Order in the Court: Why Ordering Matters in Partnership Transactions
Chapter 137. The McCauslen Two-Step: Did the Government Get it Right in Revenue Ruling 99-6?
Chapter 138. The Treatment of Liabilities in Rev. Rul. 99-5 and Rev. Rul. 99-6 Situations
Chapter 139. Operational Issues of Section 751 (b)—Current and Future (PowerPoint Slides)
Chapter 140. Blissful Ignorance: Section 751(b) Uncharted Territory
Chapter 141. Cover Letter Dated November 28, 2006 from Kimberly S. Blanchard to Eric Solomon and the Honorable Mark W. Everson Enclosing New York State Bar Association Tax Section’s Report Number 1122 Responding to Notice 2006-14 Relating to the Treatment of Partnership Distributions Under Section 751(b)
Chapter 142. Final Partnership Merger and Division Regulations—Analysis, Commentary and Examples
Chapter 143. Applying Sections 704(c) and 737 in Partnership Mergers and Divisions
Chapter 144. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 145. Partnership Mergers and Divisions: A User’s Guide
Chapter 146. Partnership Mergers and Divisions
Chapter 147. Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 148. Partnership Mergers: The Saga Continues
Chapter 149. Transactional Planning Under the Partnership Merger & Division Regulations
Chapter 150. Mergers and Divisions of Partnerships
Chapter 151. Mergers and Divisions of Partnerships (PowerPoint Slides)
Chapter 152. Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong?
Chapter 153. Mapping the Labyrinth: Partnership Mergers and Divisions
Chapter 154. Recapitalization of Partnerships: General Issues Under Subchapter K
Chapter 155. M&A Transactions Involving Partnerships and LLCs, Including Conversions, Mergers and Divisions
Chapter 156. Adjustments to the Basis of Partnership Assets
Chapter 157. Partnership Tax Strategies and Pitfalls Using (and Avoiding the Use of) the Section 754 Election (PowerPoint Slides)
Chapter 158. Dealing with the Service’s Interim Guidance on Downward Basis Adjustments Under 734 and 743
Chapter 159. Jobs Act Tightens Partnership Tax Rules
Chapter 160. Bipolar Disorder and the Section 743/755 Regulations
Chapter 161. Bipolar Disorder and the Section 734/755 Regulations
Chapter 162. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition In UPREIT and Other Partnership Contribution Transactions
Chapter 163. Tiers in Your Eyes: Peeling Back the Layers on Tiered Partnerships
Chapter 164. The “Check-the-Box” Regulations: Elective Entity Classification Under Section 7701
Chapter 165. Tax Planning for Single Member Entities: Check-the-Box, Qualified REIT Subsidiaries and S-Corp Subsidiaries
Chapter 166. Entity Identity: The Taxation of Quasi-Separate Enterprises
Chapter 167. Tax Classification of Segregated Portfolio Companies
Chapter 168. Series LLCs and the Abolition of the Tax System
Chapter 169. Series LLCs: The Loaves and Fishes of Subchapter K
Chapter 170. Taxation Meets Bizarro World: Passthroughs and Debt Workouts
Chapter 171. Use of Limited Liability Companies in Corporate Transactions
Chapter 172. Disregarded Entities in Corporate Transactions
Chapter 173. Translating Corporate Concepts into the Language of LLCs
Chapter 174. Through the Looking Glass: Seeing Corporate Problems as Partnership Opportunities
Chapter 175. How and When to Apply Step Transaction Doctrine in Corporate and Partnership Restructuring Transactions
Chapter 176. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 177. The Use of Partnerships and LLCs in Structuring Consolidated Groups
Chapter 178. Handling UPREIT and DownREIT Transactions: Latest Techniques and Issues
Chapter 179. Taxation of Real Estate Investment Trusts and Shareholders
Chapter 180. IRS Clarifies Tax Treatment of Foreign Governments Investing in REITs, Highlighting Tax Planning Opportunities
Chapter 181. The Private REIT: Selected Tax Issues
Chapter 182. Some Comments on REITs and Partnerships—Part I
Chapter 183. The S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
Chapter 184. Section 1031 Exchanges Involving Tenancies-in-Common
Chapter 185. How to Keep the TICs from Biting
Chapter 186. The ‘State of the Art’ in Like-Kind Exchanges, 2009
Chapter 187. Tax Court Again Rejects Purchase from a Related Person of 1031 Replacement Property
Chapter 188. Community Property Partnerships and Like-Kind Exchanges
Chapter 189. Estate Planning for Real Estate Entrepreneurs
Chapter 190. Transfers to Investment Companies: Complexity in a Conundrum
Chapter 191. Selected Tax Issues in Structuring Private Equity Funds
Chapter 192. Hedge Funds—Structure, Regulation and Tax Implications Structure and Regulation
Chapter 193. U.S. Taxation of Private Equity and Hedge Funds
Chapter 194. Exploring the Reasons Behind the Bias of Private Equity and Venture Capital Firms Investing in Corporations Rather Than Limited Liability Companies—A Time to Reconsider
Chapter 195. Commentary Partnerships: From the Tax Exempt’s Perspective
Chapter 196. Investments by Tax-Exempt Organizations—Intersections and Collisions with the Taxable World
Chapter 197. Taxation of United States Tax-Exempt Entities’ Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization
Chapter 198. UBIT Issues in Investment Partnerships: What Tax-Exempt Organizations (and Their Taxable Partners) Should Know
Chapter 199. Joint Ventures with Tax-Exempt Entities and Taxable Operations (Including REITs)
Chapter 200. Help with Fractions: A Fractions Rule Primer
Chapter 201. Tax Exempt Investors in Real Estate: Tax Opportunity or Tax Trap?
Chapter 202. Possible Approaches for Avoiding UBTI on Real Estate Investments
Chapter 203. Certain U.S. Tax Considerations for Organizing U.S. Hedge Funds
Chapter 204. Cross-Border Tax Problems of Investment Funds
Chapter 205. U.S. Taxation of Tax-Exempt and Foreign Investors in U.S. Private Investment Funds
Chapter 206. Partnerships as an Alternative to Secured Loans
Chapter 207. Debt vs. Equity in the Partnership Context
Chapter 208. Partner or Lender? Debt/Equity Issues Arise in Second Circuit’s Reversal of Castle Harbour
Chapter 209. Economic, Tax, and Drafting Considerations for Preferred Partnership Interests
Chapter 210. Revival of the Choice of Entity Analysis: Use of Limited Liability Companies for Start-Up Businesses
Chapter 211. Organizing the Corporate Venture
Chapter 212. Partnerships Under the Proposed Domestic Production Activities Deduction Regulations
Chapter 213. Renewable Energy Tax Credit Monetization Strategies: Opportunities and Uncertainties for Partnerships
Chapter 214. Noted Trends in the State Taxation of Pass-Through Entities
Chapter 215. State Taxation of Partnerships, Limited Liability Companies and Their Owners
Chapter 216. Select Transactional Issues in State Partnership Taxation
Chapter 217. Limited Liability Company Conversions—Navigating the State Tax Implications
Chapter 218. Publicly Traded Partnerships
Chapter 219. Section 7704 and Publicly (or Non Publicly) Traded Partnerships
Chapter 220. Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 221. Triangles in a World of Squares: A Primer on Significant U.S. Federal Income Tax Issues for Natural Resources Publicly Traded Partnerships (Part I)
Chapter 222. Triangles in a World of Squares: A Primer on Significant U.S. Federal Income Tax Issues for Natural Resources Publicly Traded Partnerships (Part II—Property Acquisitions)
Chapter 223. Present Value and Internal Rate of Return
Chapter 224. United States Federal Taxation of Derivatives: One Way or Many?
Chapter 225. Debt Workouts: The Partnership and the Partners
Chapter 226. Partnership COD Income and Other Debt Issues
Chapter 227. NYC Bar Reports on Accounting for Interest on Nonperforming Loans
Chapter 228. Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss
Chapter 229. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 230. Worthless Partnership Interests
Chapter 231. Real Estate Workouts—A Step by Step Analysis
Chapter 232. Partner Guarantees in Debt Workouts
Chapter 233. The 2009-2010 Special Election to Defer Cancellation of Debt Income
Chapter 234. Debt Workout Issues for REITs are Complicated, Whether They are Debtors or Creditors
Chapter 235. Partnership Bankruptcy Tax Issues
Chapter 236. IRS Attempts to “Demonize” the Partnership: The Final Section 701 Regulations—Antiabuse Regulations or Simply Abusive Regulations?
Chapter 237. Final Partnership Anti-Abuse Regulations—Key Issues and Examples
Chapter 238. Short History of Tax Shelters
Chapter 239. Joint Committee on Taxation, Background and Present Law Relating to Tax Shelters (JCX-19-02, March 19, 2003)
Chapter 240. Joint Committee on Taxation: Report of Investigation of Enron Corporation and Related Entities Regarding Federal Tax and Compensation Issues, and Policy Recommendations (Excerpts Relating to Partnership Tax Issues
Chapter 241. Broad Scope of Section 470 Catches Many Non-Abusive Transactions
Chapter 242. Here Comes the Kitchen Sink: IRS Throws “Everything But” at Two Partnership Tax Deferral Structures
Chapter 243. Son of BOSS Transactions: Taxpayers Win the First Round in Klamath
Chapter 244. What Will Be the Impact of the Government’s Victory in Coltec?
Chapter 245. What Will Be the Long-Term Impact of the Sixth Circuit’s Divided Decision in Dow Chemical?
Chapter 246. Will Black & Decker Turn Out to Be a Pyrrhic Victory for the IRS?
Chapter 247. When Common Sense Failed: Long Term Capital Management Decision and Its Implications for Tax Planning
Chapter 248. Klamath Dispatches Another Tax Shelter, but Without Penalties
Chapter 249. LILO Transaction Upset by District Court on Motion for Summary Judgment in BB&T
Chapter 250. ‘Son of BOSS’ Update: Summary Judgment on the Tax Liability in Cemco but No Fraud in Sala
Chapter 251. Son-Of-BOSS Revisited
Chapter 252. IRS Goes “Over the Top” in Attacking State Tax Credit Partnerships
Chapter 253. Taxable Sale or Nontaxable Reorganization? Tax Court Draws a Distinction in Tribune Company
Chapter 254. Court of Federal Claims Rejects Taxpayer’s Claims of a Business Purpose in Heinz
Chapter 255. Schering-Plough: IRS Trains Its Business Purpose and Economic Substance Weaponry on Deemed Repatriation Strategies
Chapter 256. IRS Slams the Brakes on a Loss Acceleration Strategy: CCA 200849012 Challenges Sophisticated Technique to Recognize Losses On Accounts Receivable
Chapter 257. No ‘Bliss’ in New Phoenix Sunrise—Tax Court Rejects and Penalizes a Tax Shelter Transaction
Chapter 258. CA-7 Sinks Penalties in One Son-of-BOSS Case, While Reg 1.752-6 Is Torpedoed Again in Another
Chapter 259. Castle Harbour III: A Taxpayer Victory as the District Court Refuses to Surrender
Chapter 260. Castle Harbour Strikes Again
Chapter 261. Bad Facts Result in a Taxpayer Loss in the First SILO Case to Be Adjudicated
Chapter 262. In Klamath, the Fifth Circuit Clarifies Its Test for Economic Substance
Chapter 263. Avoiding Penalties with Tax Opinions After Long Term Capital
Chapter 264. Partnerships in the Courts: Case Law Update
Chapter 265. Tax Shelters: Evaluating Recent Developments
Chapter 266. Code Sec. 6111 and the Partnership Tax Practitioner
Chapter 267. Final Corporate Tax Shelter Disclosure and List Maintenance Regulations Impose Burdens on Everyone
Chapter 268. Circular 230 and Tax Shelters in 2009
Chapter 269. Final Regulations for the Tax Shelter Disclosure Regime—Making the Rules More User Friendly
Chapter 270. Detection & Dissection: How the IRS Identifies and Combats Tax Shelters and Regulates Those Who Advise on Aggressive Transactions
Chapter 271. Shelters, Schemes, and Abusive Transactions: Why Today’s Thoughtful U.S. Tax Advisors Should Tell Their Clients to “Just Say No”
Chapter 272. Misuse of Anti-Abuse
Chapter 273. Reliance on Tax Opinions: The World Changes Due to Long Term Capital Holdings and the AJCA
Chapter 274. The World Changes: Broad Sweep of New Tax Shelter Rules in AJCA and Circular 230 Affect Everyone
Chapter 275. What Hath Congress Wrought? Amended Section 6694 Will Cause Problems for Everyone
Chapter 276. Privileged Communications in the Context of U.S. Tax Practice
Chapter 277. Strategies for Defending Against Discovery Requests for Tax Returns
Chapter 278. War of the [Tax] Worlds: Privilege Versus Transparency
Chapter 279. International Joint Venture Issues and Planning With an Emphasis on Utilizing Partnership Structures
Chapter 280. Foreign Partnerships Cross Border Planning
Chapter 281. Venturing Afar: Structural Tax Considerations in Cross-Border Joint Ventures
Chapter 282. International Joint Ventures: Basic Tax Goals and Structures
Chapter 283. International Joint Ventures: Basic Tax Goals and Structures (PowerPoint Slides)
Chapter 284. International Joint Ventures
Chapter 285. The Anti-Inversion Provisions of Internal Revenue Code Section 7874
Chapter 286. Cover Letter Dated January 3, 2007 from Kimberly S. Blanchard to Eric Solomon and the Honorable Mark W. Everson Enclosing New York State Bar Association Tax Section’s Report Number 1124 on Differences in Tax Treatment of Domestic and Foreign Partnerships
Chapter 287. ETB and Foreign Lenders
Chapter 288. Opportunities for the Foreign Investor in U.S. Real Estate—If Planning Comes First
Chapter 289. The U.S. Tax Effects of Choice of Entities for Foreign Investment in U.S. Real Estate and Businesses and the Taxation of Dispositions of U.S. Partnership Interests
Chapter 290. Taxation of U.S. Individual Investor in Private Fund Exiting a Non-U.S. Project
Chapter 291. The Unresolved Tax Status of Multinational Service Partnerships and Their Partners
Chapter 292. NYC Bar Reports on Derivative Benefits Provisions in Tax Treaties
Chapter 293. CFC Stock Held By Foreign Partnerships: Confusion Galore
Chapter 294. Final Regulations Apply Subpart F to a CFC’s Distributive Share of Partnership Income
Chapter 295. Notice 2009-7: IRS Designates “Partnership Blocker” to Subpart F Inclusions as a New Transaction of Interest
Chapter 296. Partnerships Change Everything: Using a Partnership in an Outbound Stock Acquisition
Chapter 297. Foreign Partnership Reporting Requirements: Regulations Under Sections 6038, 6038B and 6046A
Chapter 298. Reporting Obligations for Foreign Partnerships
Chapter 299. Living with The 2008 Final Partnership Withholding Regulations
Chapter 300. U.S. Taxation of Foreign Partners
Chapter 301. U.S. Taxation of Foreign Partners
Chapter 302. Special Problems of Foreign Partners
Chapter 303. The Portfolio Interest Exception in the Partnership Context
Chapter 304. Uncle Sam Meets Uncle Scrooge—The Temporary Regulations on Foreign Partner Withholding
Chapter 305. At Long Last…The IRS Issues Final Regulations on Foreign Partner Withholding
Chapter 306. Wrongs and Remedies: The US Tax Treatment of Multinational Partnerships of Individuals
Chapter 307. Check-the-Box-Planning in the International Context
Chapter 308. Check-and-Sell Transactions: Proposed Regulations Withdrawn, but Still Under Attack
Chapter 309. LLCs Provide Broad Tax Planning Possibilities for Corporate Groups in Both Domestic and Cross-Border Transactions
Chapter 310. “Hybrid” Entities: Practical Application Under the Check-the-Box Regime
Chapter 311. Formation and Use of Hybrid Entities in Cross Border Transactions
Chapter 312. Check-the-Box Knows No Boundaries (At Least, for the Moment)
Chapter 313. Tax Planning with U.S. Treaties without LOB Provisions
Chapter 314. Hybrid Entities in Cross Border Transactions: The Canadian Experience—The U.S. Response
Chapter 315. Select U.S. Federal Income Tax Considerations in European Joint Ventures
Chapter 316. Joint Ventures in the United Kingdom
Chapter 317. Joint Ventures in the Netherlands
Chapter 318. Joint Ventures in Spain
Chapter 319. Joint Ventures in France
Chapter 320. Unified Reporting, Audit, and Litigation Procedures for Partnerships, LLC’s and Joint Ventures
Chapter 321. The Elective Large Partnership Rules
Chapter 322. The Uncertain Boundary Between “Partner-Level” and “Partnership-Level” Defenses Under the Partnership Audit Rule
Chapter 323. New IRS Legal Advice Vehicles: New and Improved or Needs Improvement?
Chapter 324. Attorney-Client Privilege and Work-Product Doctrine in Federal Tax Matters
Chapter 325. The Criminalization of Tax Practice
Index to Vol. 1
Index to Vol. 2
Index to Vol. 3
Index to Vol. 4
Index to Vol. 5
Index to Vol. 6
Index to Vol. 7
Index to Vol. 8
Index to Vol. 9
Index to Vol. 10
Index to Vol. 11
Index to Vol. 12
Index to Vol. 13
Index to Vol. 14
Index to Vol. 15
Index to Vol. 16