Advanced Tax Strategies for LLCs and Partnerships

Content: Intro
 Title page
 Copyright
 Chapter 1
 Allocation of Partnership and LLC Income Under Section 704(B)
 Economic Effect: The General Test
 Deemed Economic Effect
 Alternate Test for Economic Effect
 Substantiality
 Denied Allocations: Determining the Partners' or LLC Members' Interests in the Entity
 Other Issues
 Allocation of Deductions Attributable to Nonrecourse Debt
 Summary
 Chapter 2
 Allocations With Respect to Contributed Property: Section 704(c)(1)(A)
 The Traditional Method
 The Traditional Method With Curative Allocations
 The Remedial Allocations Method
 Special Rules
 Summary. Chapter 3Allocation of Partnership Recourse Liabilities Under Section 752
 How Liabilities Affect Partner Tax Consequences
 Allocation of Liabilities Among the Partners: In General
 Allocation of Recourse Liabilities
 Chapter 4
 Allocation of Partnership Nonrecourse Liabilities and Related Deductions Under Sections 752 and 704(b)
 Distinguishing Between Recourse and Nonrecourse Liabilities
 Allocation of Nonrecourse Debts
 Treatment of Contingent Liabilities
 Chapter 5
 Advanced Distribution Rules
 Non-Liquidating Distributions Generally
 Distribution of Multiple Properties
 Summary. Chapter 6Adjustments to the Basis of Partnership or LLC Assets
 Section 743: Adjustments Following the Transfer of a Partnership Interest
 Distributions of Partnership Property
 Allocating the Adjustment Amount Among Partnership Properties
 Chapter 7
 Sale of an Interest in a Partnership or LLC
 General Tax Consequences Associated With Sale
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 Assets and Section 751(a)
 Collectibles and Unrecaptured Section 1250 Gain
 Installment Sales
 Net Investment Income Tax
 Sale of an Active (Non-passive) Interest in a Partnership or LLC
 Sale of a Passive Interest in a Partnership or LLC.