Description
This course covers the treatment under federal law tax of partners and partnerships. Among the topics covered are initial and subsequent investment, carrying on of the business, withdrawal and redemption, sale of partnership interest, merger, consolidation, and dissolution and wind-up. Also examined are: the costs and benefits of doing business as a partnership versus doing business as a C corporation or S corporation; taxation of capital gains and losses versus ordinary income, the use of partnerships in tax shelters and tax controversy. Where appropriate, international implications - such as the increasing use of hybrid partnership/corporate forms, which permit the venture to use one classification domestically and another abroad - are considered.
