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716-2nd, Partnerships—Current and Liquidating Distributions; Death or Retirement of a Partner, provides a detailed discussion of the tax consequences of distributions by partnerships to partners, including those arising from distributions of a partner's share of the results of partnership operations, and other distributions by the partnership that do not result in termination of the distributee's interest in the partnership even though accompanied by a change in the distributee's and remaining partners' shares of capital or profits and losses, whether in money or property—all called current distributions—and distributions of money or property on the withdrawal of a partner whether on death or withdrawal—called liquidating distributions.

To view this Portfolio, take a free trial to Bloomberg Tax Bloomberg Tax This Portfolio is available with a subscription to Bloomberg Tax, a comprehensive research solution including over 500 Tax Management Portfolios, practice tools, primary sources and timely news. 716-2nd, Partnerships — Current and Liquidating Distributions; Death or Retirement of a Partner, provides a detailed discussion of the tax consequences of distributions by partnerships to partners, including those arising from distributions of a partner's share of the results of partnership operations, and other distributions by the partnership that do not result in termination of the distributee's interest in the partnership even though accompanied by a change in the distributee's and remaining partners' shares of capital or profits and losses, whether in money or property — all called current distributions — and distributions of money or property on the withdrawal of a partner whether on death or withdrawal — called liquidating distributions.

If the corporation distributes appreciated property, the corporation is taxed on the gain under Code § 311(b).

Finally, Part V analyzes §736, which characterizes partnership payments made to a retiring partner or the successors of a deceased partner, dividing them between those that are liquidating distributions allocable to the retiring or deceased partner's interest in the partnership (including goodwill and similar intangibles) that are governed by the principles discussed in Part IV, and any other withdrawal payments, which are classified as either distributive share payments, with their character determined by the allocable share of partnership income, or guaranteed payments, which are ordinary income to the distributee without regard to partnership income, depending on whether their amount is determined by partnership income or not, and are, in effect, deductible (or excludible) by the partnership (remaining partners). Comparison of a Current Distribution with a Loan Transaction 3.

It also addresses estate and income tax considerations relevant to a deceased partner's successors, other than those involving §736. M., Partnerships—Formation and Contributions of Property or Services; 718 T. Overview of the Rules Governing Partnership Distributions A. Characterization as a Sale Transaction or a Distribution 4.

Part I, Introduction, briefly discusses important general principles not directly related to distributions, but that will nevertheless frequently be referred to throughout the Portfolio, including partnership capital accounts, §704(c) and reverse §704(c) allocations. Basis of Property Received in a Current Distribution 1.

Part I then addresses the vexing question of distinguishing a partner withdrawal from sale of a partnership interest (which are considered in more detail in 718 T. Partnerships — Disposition of Partnership Interests or Partnership Business; Partnership Termination). Distribution of Marketable Securities (1) In General (2) Definition of Marketable Securities (3) Exceptions (a) Marketable Securities Contributed By Distributee Partner (b) Securities Not Marketable When Acquired By Partnership (c) Securities Acquired In a Nonrecognition Transaction (d) Anti–Stuffing Rule (4) Distribution By Investment Partnership (a) Investment Partnership (b) Eligible Partner (5) Limitation on Gain (6) Basis Rules (a) Basis of Distributed Securities (b) Partner's Basis in Partnership and Partnership's Basis in Other Assets (7) Character of Gain Recognized (8) Anti–Abuse Rule 2. Ordering Rules - Liabilities Assumed and Relieved D.

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