7668. Federal Taxation of Partners and Partnerships

This course is a detailed introduction to the federal tax treatment of the most common business entities in use in the United States today --partnerships and limited liability companies. The relevant tax provisions are found primarily in Subchapter K of the Internal Revenue Code. Topics to be studied in depth include: the classification of entities as partnerships for federal tax purposes; formation of the partnership and subsequent contributions to partnership capital; the flow-through tax treatment of partnership operations; tax-sensitive allocations of items of partnership income, deduction, credit and loss; partnership distributions and related tax-sheltering strategies, "collapsible partnerships;" the liquidation or sale of partnership interests; and the death or retirement of partners. The course also compares the tax treatment of partnerships with that of S corporations.