人気ブログランキング | 話題のタグを見る
nnのCPA試験の旅 in Hawaii CPA試験の旅 in Hawaii

Hello again!


by nn_77
カレンダー
S M T W T F S
1 2
3 4 5 6 7 8 9
10 11 12 13 14 15 16
17 18 19 20 21 22 23
24 25 26 27 28 29 30
31

Tax Advice

Today I reviewed the tax accounting for Partnership. Accounting for the adjusted basis of property in liquidating & nonliquidating distribution became much easier for me than before. But I noticed that my memory about many other rules about this topical area is fading away…

Among them are the rules governing the holding period of the P/S interest for a partner.
At times, a partner contributes some properties to the P/S in exchange for some percent of P/S interest. For tax accounting reason, we must determine the holding period of those properties and PS interests. Under the IRS code, the holding period of the PS interest for a partner varies according to the nature of the distributed property.

When a partner receives PS interest by contributing Cash or properties other than Capital assets or Sec 1231 Assets, the holding period of the PS interest for the partner starts when the partner received the PS interest.

What’s stated above would sound very natural to you. But it isn’t the case in the following situations.

When a partner receives PS interest by contributing Capital assets or Sec 1231 assets, the holding period of the PS interest for the partner includes the period of time that those contributed properties were held by the partners before contribution.

Besides, the holding period of the contributed property for the Partnership always includes the period of time that the partner held those properties before contribution, regardless of the character of the contributed property.

In order to confirm the above mentioned rules, I referred to The Tax Adviser (http://www.allbusiness.com/periodicals/publication/41487-1-2.html), which provides a lot of information about tax rules and useful advice for taxpayers. The real purpose of learning USCPA matters must be providing those helpful advices to clients or the company I belong to, though I don’t think I can make it that far now.

Anyway, I don’t have any single minute to waste before the exam. Gotta stick to the desk as glue!
by nn_77 | 2006-05-13 12:11 | >REG