Making Partnerships Work for Mom and Pop and Everyone Else
DePaul University - College of Law
August 17, 2011
Columbia Journal of Tax Law, Vol. 2, No. 2, 2011
MSU Legal Studies Research Paper No. 09-17
Entities treated as partnerships for tax purposes cover the spectrum from small Mom and Pop operations to mammoth enterprises owned by sophisticated partners. Designing tax law to govern this diverse array of entities is a challenging exercise since rules that are well suited to provide simplicity for entities at the small, unsophisticated end of the continuum may be poorly designed for preventing manipulation by entities at the large, sophisticated end of the continuum. However, a careful examination of how tax rules can best promote simplicity reveals opportunities for reform that would make the law more appropriate for entities all along the continuum.
Number of Pages in PDF File: 56
Keywords: Partnership Tax, Complexity, Section 704(c), Section 754
Date posted: August 18, 2011
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