Feeds:
Posts
Comments

Archive for June 1st, 2012

Since last Friday was a quasi-holiday, the week in review never got published, so we’ll cover two weeks today.

In the biggest news of the week, a California entrepeneur watches a $19M charitable contribution deduction go up in smoke for failure to follow appraisal/substantiation rules.

The IRS issues proposed regulations under Section 83 and guidance on how to account for partnership liabilities in determining a partner’s insolvency.

A dad welcomes his newborn daughter to the world with help from his best friend

Revenue Rulings 99-5 and 99-6, explained (hopefully).

 

 

Read Full Post »

After two weeks of discussing Revenue Ruling 99-6 — which governs the tax consequences resulting from the conversion of a multi-member partnership into a single-member LLC disregarded as separate from its owners — we turn our attention today to its sister authority, Revenue Ruling 99-5.

Revenue Ruling 99-5 addresses the opposite situation, providing the tax consequences of a single-member LLC taking on another partner, converting the SMLLC into a multi-member LLC.  

Like Revenue Ruling 99-6, Revenue Ruling 99-5 provides two alternative fact patterns. Today we address Situation 1, in which a new partner purchases a portion of the SMLLC interest from the sole owner. Enjoy.

Read Full Post »

Follow

Get every new post delivered to your Inbox.

Join 649 other followers