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23 May 2017, 12:00 pm
Powell: Transfer to Limited Partnership Includible in Estate, Wealth Strategies Journal (2017). [read post]
25 Jul 2017, 12:00 pm
Powell, now represents another taxpayer who failed to achieve estate tax savings through the creation and funding of a limited partnership. [read post]
14 Nov 2011, 6:00 am
Forbes recently published an article that discusses why taxpayers lose Family Limited Partnership cases. [read post]
3 Aug 2012, 7:36 am
In Estate of George H. [read post]
9 Jul 2009, 10:46 am
Section 469(h)(2) treats a limited partnership interest as presumptively passive for purposes of the passive loss rules, with the result that partnership losses cannot offset the limited partner's salary or investment income. [read post]
22 Jul 2009, 3:00 am
Section 469(h)(2) treats a limited partnership interest as presumptively passive for purposes of the passive loss rules, with the result that partnership losses cannot offset the limited partner's salary or investment income. [read post]
10 Feb 2012, 7:00 am
For some, one of those tools worthy of serious consideration is the Family Limited Partnership (FLP). [read post]
10 Jan 2012, 3:00 am
For some, one of those tools worthy of serious consideration is the Family Limited Partnership (FLP). [read post]
8 Oct 2008, 7:03 pm
" Here's the abstract: The commentary explains the operation of the section 1(h)(6)(B) limitation on gain taxed at 25% when a partner's... [read post]
21 Nov 2008, 7:00 pm
Burke explains the operation of the § 1(h)(6)(B) limitation on gain taxed at... [read post]
19 Sep 2008, 3:45 pm
Here is the abstract: The commentary explains the operation of the § 1(h)(6)(B) limitation on gain taxed at 25% when a partner's only capital gain... [read post]
13 Jan 2018, 6:45 am
By now, the standard conventions in most Limited Partnership Agreements (LPAs) are well understood by most observers and students of the industry—most investment managers (general partners, or GPs) charge 1.5% to 2.5% management fees to their investors (the limited partners, or LPs), and take a 20% carried interest in the net return in the exited investments, resulting in the “2 and 20” compensation structure that is commonplace in private equity. [read post]
3 Jul 2009, 2:08 am
The issue involved Sec. 469(h)(2) which states, Except as provided in regulations, no interest in a limited partnership as a limited partner shall be treated as an interest with respect to which a taxpayer materially participates. [read post]
10 Mar 2017, 8:06 am
On the other hand, Indian businesses—long content to tackle personnel-level issues like H-1B visas—have underinvested in local talent that can convince companies abroad to confidently ink partnership agreements. [read post]
18 Jun 2007, 8:32 am
--San Antonio Dec. 13, 2006, no pet. h.)). [read post]
12 Jun 2008, 7:09 pm
Separate Property of Each PartyThe parties wish to identify what will remain the separate property of each party during the domestic partnership, and to determine their rights in the event of a separation or dissolution of their domestic partnership, as hereinafter discussed.The following shall constitute and remain the “separate property” of the respective parties: (a) property, whether real or personal, and whether vested, contingent, or inchoate, belonging to or… [read post]
25 Jul 2011, 1:39 pm
The special limited partner would receive a percentage of the general partnership’s stake, so the ability to repay the special limited partner depended in significant part on the amount invested in the fund given the annual 2 percent management fee. [read post]
6 Nov 2017, 1:44 pm
Separate Property of Each PartyThe parties wish to identify what will remain the separate property of each party during the domestic partnership, and to determine their rights in the event of a separation or dissolution of their domestic partnership, as hereinafter discussed.The following shall constitute and remain the “separate property” of the respective parties: (a) property, whether real or personal, and whether vested, contingent, or inchoate, belonging to or… [read post]
26 Oct 2012, 4:23 am
Trustee's ability to liquidate the Partnership assets does not originate with remedies under § 363(h). [read post]
10 Dec 2010, 9:45 pm
" H/t to the always insightful eNews from the Institutional Religious Freedom Alliance. [read post]
