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