Chapter 11: Partnerships & LLCs

In this section

• Formation & Contributions (§721) with Built-In Gain/Loss Property
  Explore how §721 impacts nonrecognition of gain or loss upon formation of partnerships and LLCs, with a focus on carrying over basis, built-in gains/losses, disguised sale rules, and intangible contributions.
• Partner’s Outside Basis vs. Partnership Inside Basis
  Comprehensive coverage of how partners track outside basis and how partnerships maintain inside basis, including formulaic approaches and the role of ownership percentages in basis adjustments.
• Special Allocations, Guaranteed Payments & §704(b)/(c) Rules
  Essential insights into special allocations of partnership items, guaranteed payments, and 704(b) and (c) rules, with in-depth discussions on substantial economic effect testing, and illustrative examples of guaranteed payments versus distributive share.
• Distributions (Liquidating, Nonliquidating) & Disguised Sales
  Deep dive into partnership and LLC distributions, focusing on basis adjustments, liquidating vs. nonliquidating distributions, and disguised sales under the IRC.