LLM Tax Partnership

The course explores the federal income tax concepts of pass through or conduit taxation. Partnership tax topics include choice of entity decisions, partnership formations, asset contributions, liability assumption, distributions, operations, transfer of partners interests, special allocations of tax attributes, partnership interests received for services, special basis adjustments, and analysis of the entity and aggregate approaches found in the law. Also included is an introduction to the study of the law of S-Corporations and how it compares to the taxation of partnerships.