Transcription of LB&I Transaction Unit - IRS tax forms
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LB&I Transaction Unit - IRS tax forms
LB&I Transaction UnitUnit NameSale of a partnership InterestPrimary UIL and Character of Gain or Loss on Sale or ExchangeLibrary LevelTitleKnowledge BasePartnership Knowledge BaseShelfDispositions, Divisions and MergersBookDispositionsChapterSale or Exchange of partnership InterestDocument Control Number (DCN)PAR-T-006 Date of Last Update02/19/21 Note: This document is not an official pronouncement of law, and cannot be used, cited or relied upon as such. Further, this document may not contain a comprehensive discussion of all pertinent issues or law or the IRS's interpretation of current of Contents(View this PowerPoint in Presentation View to click on the links below)General Overview Issue and Transaction Overview Transaction and Fact PatternSummary of Potential Issues Index of Referenced ResourcesTraining and Additional ResourcesGlossary of Terms and AcronymsIndex of Related Practice Units3 Issue and Transaction OverviewSale of a partnership Interest When a sale of a partnership interest occurs, the entity theoryis the underlying concept, not the aggregate theory.
A partner may dispose of an interest in a partnership in different ways - sale, exchange, gift, death or abandonment. This transaction unit focuses on the tax issues related to the sale of a partnership interest. Ensure the transaction was a sale of a partnership interest and not some other transaction such as a liquidation or non- taxable ...
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