Deductible payments to departing partners - the RRA and its impact on LLCs. (Revenue Reconciliation Act of 1993, limited liability companies): An article from: The Tax Adviser
Book Details
Author(s)N. Patricia Kurtz, Dean A. Rocheleau
PublisherAmerican Institute of CPA's
ISBN / ASINB00092U0TK
ISBN-13978B00092U0T3
AvailabilityAvailable for download now
MarketplaceUnited States 🇺🇸
Description
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on December 1, 1993. The length of the article is 1521 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: Changes in the tax treatment of liquidation payments to a departing partner for unstated goodwill and unrealized receivables are limited to partnerships where capital is a material income-producing factor. These changes can alsoaffect payments to a partner departing a limited liability company (LLC). Though the pay-out is non-deductible to partnerships where capital is a material income-producing factor, professional partnerships can still deduct payments for receivables and goodwill. This exception only applies to departing general partners. State law typically finds LLC partners are not general partners, so LLCs may be denied the deduction made available by the exception.
Citation Details
Title: Deductible payments to departing partners - the RRA and its impact on LLCs. (Revenue Reconciliation Act of 1993, limited liability companies)
Author: N. Patricia Kurtz
Publication:The Tax Adviser (Magazine/Journal)
Date: December 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n12 Page: 773(4)
Distributed by Thomson Gale
From the supplier: Changes in the tax treatment of liquidation payments to a departing partner for unstated goodwill and unrealized receivables are limited to partnerships where capital is a material income-producing factor. These changes can alsoaffect payments to a partner departing a limited liability company (LLC). Though the pay-out is non-deductible to partnerships where capital is a material income-producing factor, professional partnerships can still deduct payments for receivables and goodwill. This exception only applies to departing general partners. State law typically finds LLC partners are not general partners, so LLCs may be denied the deduction made available by the exception.
Citation Details
Title: Deductible payments to departing partners - the RRA and its impact on LLCs. (Revenue Reconciliation Act of 1993, limited liability companies)
Author: N. Patricia Kurtz
Publication:The Tax Adviser (Magazine/Journal)
Date: December 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n12 Page: 773(4)
Distributed by Thomson Gale
