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Defining partnerships and partners for tax purposes
Formation of the partnership
Outside basis and allocation of liabilities
Operation of the partnership : calculation of partnership taxable income
Operation of a partnership : allocation of partnership income and losses
Dispositions of partnership interests
Partnership distributions
Transactions between partner and partnership : issuance of a partnership interest for services
Business combinations : partnership mergers and divisions
Partnership options
I.R.C. : 197 intangibles amortization
Foreign partnerships, foreign partners and partnerships with tax-exempt entities
Anti-abuse provisions.
Formation of the partnership
Outside basis and allocation of liabilities
Operation of the partnership : calculation of partnership taxable income
Operation of a partnership : allocation of partnership income and losses
Dispositions of partnership interests
Partnership distributions
Transactions between partner and partnership : issuance of a partnership interest for services
Business combinations : partnership mergers and divisions
Partnership options
I.R.C. : 197 intangibles amortization
Foreign partnerships, foreign partners and partnerships with tax-exempt entities
Anti-abuse provisions.