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Tax consequences of the departure of a partner or an S corporation shareholder

Article Abstract:

The Revenue Reconciliation Act of 1993 makes an important change in liquidation payment treatment for partnership or S corporation interests by amending IRC section 736's treatment of unrealized receivables and goodwill. The previous law would have treated payments as distributive shares for which the remaining partners would receive a deduction. However, as amended, section 736 treats payments as exchanges for the partnership interest being liquidated unless capital is not a material income-producing factor and the payments are made to a general partner.

Taxation, S corporations

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Determining a partner's share of unrealized receivables at the liquidation of the partner's interest

Article Abstract:

The author discusses the tax consequences of IRC sections 736(b) and 751(b) in regards to determining partners' shares of unrealized receivables at the time of liquidation.

Valuation

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Corporate restructuring through partial liquidations

Article Abstract:

The author discusses the use of partial liquidations with subsidiary corporations' restructuring and pitfalls to be aware of to avoid double taxation.

Subsidiary corporations, Subsidiaries, Corporate reorganizations, Double taxation

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