Federal Partnership Taxation
Policy and Theoretical Dimensions of Qualified Tax Partnerships, Kansas Law Review (2008)
Qualified tax partnerships are arrangements that come within the definition of tax partnership but elect...
Taxation
Residual-Risk Model for Classifying Tax Entities, ExpressO (2008)
The current model for classifying tax entities enables sophisticated taxpayers to privately affect the placement...
Taxation-Federal Income
Profits-Only Partnership Interests, Brooklyn Law Review (2009)
Profits-only partnership interests grant service-providing partners an interest in the profits of a partnership but...
The Aggregate-Plus Theory of Partnership Taxation, Georgia Law Review (2009)
This Article presents a theory of partnership taxation. To provide context for the presentation, the...
A Win-Win Proposal for Analyzing Profits-Only Partnership Interests, Tax Notes (2008)
The proper tax treatment of profits-only partnership interests is an unsolved aspect of tax law....
The Like-Kind Exchange Equity Conundrum, Florida Law Review (2008)
The tax-free treatment of like-kind exchanges presents one of tax law’s most compelling equity conundrums....
Policy and Theoretical Dimensions of Qualified Tax Partnerships, Kansas Law Review (2008)
Qualified tax partnerships are arrangements that come within the definition of tax partnership but elect...
Tax-Free Swaps: Using Section 1031 Like-Kind Exchanges to Preserve Investment Net Worth (2007)
Property owners of all sizes realize that exchanging property under section 1031 presents tax-saving possibilities....
Related-Party Like-Kind Exchanges (with Kelly Alton and Alan Lederman), Tax Notes (2007)
Related-party exchanges under section 1031 raise many technical, theoretical, and policy issues. Unfortunately, this topic...
Section 1031 and Proximate and Midstream Business Transactions, Tax Management Real Estate Journal (2003)
Section 1031 exchanges frequently occur in proximity to business transactions (i.e., entity formations, mergers, divisions,...
No subject area
Like-Kind Exchanges of Personal-Use Residences (with Alex Hamrick), Tax Notes (2008)
The law governing section 1031 exchanges of personal-use residences ranges from very explicit, in the...
Partnership Tax Allocations and the Internalization of Tax-Item Transactions, South Carolina Law Review (2008)
Studies in the theory of the firm help explain partnership attributes and the relationships partners...
Safe Harbors and Careful Planning Make Deferred Exchanges a Valuable Tool, Journal of Taxation of Investments (2008)
This Article describes the section 1031 deferred exchange safe harbors. It describes how property owners...
Tax-Free Like-Kind Exchanges (2008)
This is a comprehensive treatise on section 1031 like-kind exchanges.
Tax Opinions in TIC Offerings and Reverse TIC Exchanges (with Todd D. Keator), Tax Management Real Estate Journal (2007)
Property owners often acquire tenancy-in-common (TIC) interests as replacement property in section 1031 exchanges. Generally,...
Section 1031 Alchemy: Transforming Personal Tangible and Intangible Property Into Real Property (with Kelly E. Alton), Real Estate Taxation (2007)
Section 1031 nonrecognition applies only to exchanges of like-kind properties. Although real property generally is...
The Federal Definition of Tax Partnership, Houston Law Review (2006)
The federal definition of tax partnership determines who will be subject to partnership tax law...
Rev. Proc. 2004-51: The IRS Strikes Back (with Kelly E. Alton and Alan S. Lederman), Taxes: The Tax Magazine (2005)
Perhaps the most controversial income tax question in the real estate industry in 2004 was...
The Whole Truth About Using Partial Real Estate Interests in Section 1031 Exchanges, Real Estate Taxation (2003)
A myth persists. Many believe that section 1031 treats all real property as like kind...
What You Should Know About Mergers and Divisions of Partnerships, The Practical Tax Lawyer (2003)
This article explains the tax consquences of partnership mergers and divisions and describes planning opportunities...
Reverse Like-Kind Exchanges: A Principled Approach, Virginia Tax Review (2001)
Even with the Internal Revenue Service's publishing Rev. Proc. 2000-37, there is no authoritative guidance...