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Partnership Basis
In previous articles the issue surrounding a variance in inside and outside basis has been discussed and examples provided.  Now the question arises, can the issue be fixed?  The article below has been prepared by a Denver tax attorney at The McGuire Law Firm to further this discussion and to discuss the 754 election. In...
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In a previous article a tax attorney at The McGuire Law Firm drafted an article regarding inside and outside basis in a partnership to later further a discussion on IRC Section 754.  The article below will continue to discuss inside and outside basis and the problems or issues that can occur as we move forward...
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Recently an issue came about regarding IRC Section 754 and it’s application to partnership matters.  The article below has been drafted by a Denver tax attorney at The McGuire Law Firm to initially discuss inside and outside basis, which will help to understand IRC Section 754. When you hear the term “outside basis” in reference...
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As you may or may not know, a partnership is a pass through entity whereby items of income, gain, loss, deduction or credit are passed through to the individual partners and reported on their 1040 individual income tax returns.  The article below has been drafted by a Denver tax attorney at The McGuire Law firm...
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So you have worked hard with your partners and built a strong and respectful business.  Now you wish to sell your partnership interest.  Maybe you are looking to retire, or maybe you just want to try a new endeavor, but regardless you are going to sell your partnership interest.  As you begin the process, a...
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Under the 752 Treasury Regulations, if through a single transaction, a partner incurs both an increase and a decrease in the partner’s share of the partnership liabilities, only the net increase is treated as a contribution of money and only the net decrease is treated as a distribution of from the partnership.  Below is an...
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Under Internal Revenue Code section 752(a) an increase in a partner’s share of partnership liabilities, or an increase in a partner’s individual liabilities by reason of the assumption by such partner of a partnership liability or liabilities, shall be considered as a contribution of money by such partner to the partnership.  Because the assumption of...
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As a tax attorney and business attorney, John McGuire frequently works with a partner within a partnership who contributes property to a partnership such as an LLC and the partnership assumes the liability on the property.  When this occurs, a tax attorney will advise the contributing partner that their basis is decreased by the sum...
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Recourse and Nonrecourse Debt in an LLC  As a tax attorney and business attorney, John McGuire of The McGuire Law Firm works with partnerships regarding the impact of partnership debt and the impact of recourse and nonrecourse debt.  The article below outlines law to consider regarding partnership debt.  If you have a question regarding partnership...
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