Taxation U.S.

Partnership Taxation, Second Edition 2008

Edited by Walter D. Schwidetzky · Charles Fassler · Paul D. Carman · Richard M. Lipton
LexisNexis Matthew Bender January 2008

Specifications

ISBN-13
9781422417553
Publisher
LexisNexis Matthew Bender
Publication
January 2008
Format
Hardback , 384 pages
Jurisdiction
U.S. ? Countri(es) for reference only

Details

This new edition of Partnership Taxation is one of several new releases from the LexisNexis Graduate Tax Series.

This book contains a thorough discussion of the rules of partnership taxation—when a partnership exists, the tax treatment of contributions to a partnership, the basis of partnership assets and interests in a partnership, how income is allocated to the partners, the tax treatment of distributions, the consequences of partnership liabilities, partnership mergers, the retirement of a partner and dissolution of the partnership.

There is also significant attention paid to the numerous “anti-abuse” rules that have been adopted by Congress and the IRS over the past several decades, including the disguised sale rules, the treatment of “mixing-bowl” transactions, the complex rules to prevent basis abuse, and the overriding “partnership anti-abuse regulations” adopted by the IRS.

In addition, this book explores one of the fundamental questions which always arises in partnership taxation—is a partnership to be treated as a separate taxable entity or an aggregate of its partners.

The tension between entity and aggregate treatment of a partnership is one of the recurring issues in determining the tax consequences of partnership transactions.

About the Author

Walter D. Schwidetzky

 

Walter D. Schwidetzky is a Professor of Law at the University of Baltimore School of Law. Professor Schwidetzky joined the faculty in 1985 and served as the director of the Graduate Tax Program from 1989 to 2000. Prior to joining the faculty, he practiced law in Denver, Colorado, for six years, concentrating in tax and business law. He was also an adjunct professor at the University of Denver College of Law.

Professor Schwidetzky co-authors Partnership Taxation. He also wrote the chapter on capital gains for the Matthew Bender Federal Tax Series. He has published several articles in the University of Virginia's Virginia Tax Review, and has also published articles in the Tax Lawyer, Tulane Law Review, University of Oklahoma Law Review, Southern Methodist University Law Journal, Northwestern Journal of International Law and Business, American University Journal of International Law and Policy, University of Baltimore Law Review, Taxation for Lawyers, Tax Management Real Estate Journal, Complete Lawyer and theColorado Lawyer, among others.

Professor Schwidetzky is a member of the Partnership and LLC Committee of the Tax Section of the American Bar Association, and is active on that committee's LLC Subcommittee. He frequently lectures on tax matters and has lectured for the ABA Tax Section, the ABA Real Property, Probate and Trust Law Section, the Maryland Institute for the Continuing Professional Education of Lawyers (MICPEL), and other organizations. He is a member of Phi Beta Kappa, the Order of St. Ives, and the Colorado Bar.

LL.M., University of Denver, 1984
J.D., M.B.A., University of Denver, 1978
B.A., University of Denver, 1974

Charles Fassler

 

Charles Fassler is a member of the Tax and Finance Practice Group at Bingham Greenebaum Doll LLP in Louisville, Kentucky. He deals with all aspects of Federal income taxation from a transactional perspective, with particular emphasis on partnership taxation, corporate taxation and nonqualified executive compensation. In his transactional practice, he does a considerable amount of work with limited liability companies, corporations and real estate.

LL.M., Taxation, New York University School of Law, 1974.
J.D., University of Wisconsin Law School, 1970
B.S., Accounting, Brooklyn College, CUNY, 1967

Paul D. Carman

 

Paul Carman is a Partner in the Tax Department of Chapman and Cutler LLP in Chicago, Illinois. His practice focuses primarily on structuring the tax consequences of finance and investment transactions and investment vehicles. He also has extensive experience in representation of taxpayers and exempt entities in connection with a wide variety of transactional tax issues, tax compliance issues, and tax controversies, including formation, acquisition and reorganizations of corporations, partnerships and exempt entities, syndications and private placements of investment, hard industry, e-commerce and real estate ventures, leasing, synthetic leasing and like-kind exchanges. Mr. Carman was listed as a ?Super Lawyer? in Tax by Illinois Super Lawyers for the years 2006-2012.

J.D., Northwestern University School of Law, 1986.
Managing Editor, Northwestern Law Review
B.A., Kansas Wesleyan Univeristy, 1979, Valedictorian

Richard M. Lipton

 

Richard Lipton is a Partner at Baker & McKenzie LLP in Chicago, Illinois. He provides tax planning advice for corporations, partnerships and limited liability companies. He has handled numerous engagements for clients in structuring real estate transactions, including tenant-in-common and like-kind exchanges, and has given numerous speeches at organizations throughout the United States. Mr. Lipton served on the Internal Revenue Service Advisory Council, and is former chair of the Tax Section of the American Bar Association as well as the Chicago Bar Association Federal Tax Committee. He currently chairs the American College of Tax Counsel and serves as a member of the House of Delegates of the American Bar Association.

Mr. Lipton focuses on advising US and multinational clients on federal tax issues. He also has considerable experience in real estate investment trusts (REITs), real estate funds and investment in real estate by tax-exempt organizations and foreign investors. Mr. Lipton has represented large corporations in complex partnership transactions, and served as an expert witness on partnerships and partnership taxation matters. His advice includes various areas relating to tax law, including tax-exempt organizations and the rules involving UBIT, the tax consequences of bankruptcies and workouts and various tax accounting issues. He also provides tax advice to several professional sports franchises.

J.D., University of Chicago Law School, 1977
B.A., Amherst College, 1974

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