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Full-Text Articles in Law
Revocable, Irrevocable, & Short Term Trusts, Don W. Llewellyn
Revocable, Irrevocable, & Short Term Trusts, Don W. Llewellyn
William & Mary Annual Tax Conference
No abstract provided.
Constructive Cash Distributions In A Partnership: How And When They Occur, Robert S. Parker Jr., John W. Lee
Constructive Cash Distributions In A Partnership: How And When They Occur, Robert S. Parker Jr., John W. Lee
Faculty Publications
Constructive cash distributions to partners with possible concomitant severe tax impact can occur whenever a partners share of firm or individual liabilities is cut. This reduction of liabilities can be triggered by a variety of typical partnership transactions. Messrs. Parker arid Lee analyze those transactions under which there is the danger of unforeseen taxation and urge extreme caution.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Faculty Publications
In the recent Rodman case, the Tax Court has held that a partner newly admitted near year-end must report his share of the full year's partnership profits. Messrs. Lee and Parker analyze the status of retroactive partnership allocations in view of Rodman, the first decision to expressly sanction retroactive allocations of income (and implicitly of losses) to new partners, and reallocations under Section 704.