Partnership transactions--section 751 property / Todd Y. McArthur.

Arlington, VA : Tax Management, [©2006]-

1 online resource.

Updated irregularly.

Tax management portfolios ; 720-2nd.

" ... analyzes the federal income tax consequences of (1) a sale or exchange of a partnership interest where the partnership owns a [section] 751(a) property (i.e., unrealized receivables and inventory items) and (2) a distribution from a partnership owning [section] 751(b) property (i.e., unrealized receivables and inventory items which have appreciated substantially in value) where such distribution has the effect of changing the proportionate interests of the partners in the [section] 751(b) property. Sale of a partnership interest generally gives the selling partner capital gain. Section 751, however, recharacterizes a portion of the amount realized as ordinary income to the partner, at times even in the absence of realized gain. The amount so recharacterized roughly corresponds to the amount of ordinary income the partnership would have if it sold the [section] 751(a) property, thus preventing a partner from converting into a capital gain the ordinary income that would pass through if the partnership sold the property."

Revised edition of: Partnership transactions--section 751 property / by A.L. Suwalsky.
Published: Washington, D.C., 2006-2007.

Includes bibliographical references.

Also issued in print.

Mode of access: World Wide Web.

Title from title screen (viewed Oct. 4, 2007).

www

Print version: McArthur, Todd Y. Partnership transactions--section 751 property. Washington, D.C. : Tax Management, ©2006-

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