Transcription of Sale of a Partnership Interests - taxtaxtax.com
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Sale of a Partnership Interests - taxtaxtax.com
Sale of a Partnership Interests In general, the Partnership provisions in Subchapter K of the Code adopt an entity approach . in dealing with the tax consequences of a transfer of a Partnership interest . The transferred interest is treated like corporate stock. Thus, it is primarily considered to be a separate intangible asset, rather than an undivided tenancy-in-common interest in the Partnership assets as it would be treated under an aggregate approach to Partnership taxation. See Code Sec. 741 , Reg (a) and Reg (b) . However, there are several exceptions to this rule. For instance, where the Partnership has Code Sec. 751 assets, a sale or exchange of a Partnership interest is looked through and the gain or loss on the portion allocable to those assets is treated as ordinary income or loss.
1 Sale of a Partnership Interests In general, the partnership provisions in Subchapter K of the Code adopt an “entity approach” in dealing with the tax consequences of a transfer of a partnership interest.
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