Schwarz, Lathrope, and Hellwig's Fundamentals of Partnership Taxation, Cases and Materials, 11th
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Description
- The deduction under § 199A for 20% of qualified business income from a pass-through entity. The discussion incorporates the final regulations, and includes a new problem set.
- The impact on choice of entity of the 21% corporate income tax rate, lower individual income tax rates, the 20% deduction for qualified business income, and other tax and business planning considerations.
- The three-year long-term holding period required by § 1061 for capital gains allocable to service partners with carried interests.
- Final, temporary and proposed regulations on partnership liabilities and the special treatment of bottom dollar payment obligations.
- New limitations in § 461(l) on excess business losses.
- Technical changes to Subchapter K, including the expanded definition of “substantial built-in loss” under § 743(b) and repeal of the technical termination rule in § 708.
- S corporation developments, including the requirement to pay reasonable compensation to shareholder-employees for purposes of the § 199A qualified business income deduction.
