Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 6 of 6
Full-Text Articles in Law
Succession And Estate Planning For The Small Business And Owner, Samuel Donaldson
Succession And Estate Planning For The Small Business And Owner, Samuel Donaldson
Samuel A. Donaldson
No abstract provided.
The Estate Planner's Guide To S Corporations, Samuel Donaldson
The Estate Planner's Guide To S Corporations, Samuel Donaldson
Samuel A. Donaldson
No abstract provided.
Super-Recognition And The Return-To-Sender Exception: The Federal Income Tax Problems Of Liquidating The Family Limited Partnership, Samuel Donaldson
Super-Recognition And The Return-To-Sender Exception: The Federal Income Tax Problems Of Liquidating The Family Limited Partnership, Samuel Donaldson
Samuel A. Donaldson
This article discusses three income tax rules that can cause partners to recognize gain for federal income tax purposes upon the liquidation of a family limited partnership: §§ 704(c)(1)(B), 731(c), and 737. From a policy perspective, the application of these rules to traditional family limited partnerships creates two problems. These problems are illustrated through the use of a hypothetical case study. The first problem (which arises where the partnership holds loss property) is that of super-recognition, where a partner recognizes more gain from the liquidation than he or she would recognize upon a sale of his or her partnership interest. …
Liquidation Of The Family Partnership: The Taming Of The Shrewd, Samuel Donaldson
Liquidation Of The Family Partnership: The Taming Of The Shrewd, Samuel Donaldson
Samuel A. Donaldson
Family partnerships and family limited liability companies are typically formed for reasons of efficiency, succession, and valuation. But all good things come to an end. Owners of a family partnership opt for liquidation in a variety of situations, usually following the death of the founding owner(s). Although most practitioners recall that the liquidation of a partnership is not a taxable event, few remember that as many as three Code provisions can come into play upon the liquidation of a family partnership. This article reviews those potential income tax traps and uses two examples to illustrate their coordination and application in …
Income Tax Aspects Of Family Limited Partnerships, Samuel Donaldson
Income Tax Aspects Of Family Limited Partnerships, Samuel Donaldson
Samuel A. Donaldson
No abstract provided.
Determining Treaty Eligibility For Hybrid Entities And Their Owners, Philip Postlewaite, Samuel Donaldson, Allison Christians
Determining Treaty Eligibility For Hybrid Entities And Their Owners, Philip Postlewaite, Samuel Donaldson, Allison Christians
Samuel A. Donaldson
No abstract provided.