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Tax Law

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Tufts

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Full-Text Articles in Law

Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke Dec 2015

Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke

Karen Burke

The rise of limited liability companies (LLCs) classified as partnerships for federal income tax purposes challenges traditional assumptions concerning the treatment of recourse and nonrecourse liabilities under Subchapter K. The complex rules of sections 704(b) and 752 give little attention to liabilities that are recourse to the entity under section 1001 but for which no member bears the economic risk of loss under section 752. In comparison to traditional general or limited partnerships, however, LLCs are much more likely to incur such "exculpatory" liabilities because of the limited liability shield under state law. Although exculpatory liabilities are functionally quite similar …


Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke Aug 2015

Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke

Karen Burke

The rise of limited liability companies (LLCs) classified as partnerships for federal income tax purposes challenges traditional assumptions concerning the treatment of recourse and nonrecourse liabilities under Subchapter K. The complex rules of sections 704(b) and 752 give little attention to liabilities that are recourse to the entity under section 1001 but for which no member bears the economic risk of loss under section 752. In comparison to traditional general or limited partnerships, however, LLCs are much more likely to incur such "exculpatory" liabilities because of the limited liability shield under state law. Although exculpatory liabilities are functionally quite similar …


Did Zarin Have A Tufts Day At A Casino Made Out Of Kirby Lumber?, I Jay Katz Jan 1993

Did Zarin Have A Tufts Day At A Casino Made Out Of Kirby Lumber?, I Jay Katz

Irwin J Katz

No abstract provided.