Abstract

http://ssrn.com/abstract=2374026
 


 



Avoiding Adverse Tax Consequences in Partnership and LLC Reorganizations


Bradley T. Borden


Brooklyn Law School

Brian O'Connor


Venable, LLP

Steven R. Schneider


Miller & Chevalier

December 20, 2013

Brooklyn Law School, Legal Studies Paper No. 363

Abstract:     
This article examines the alternative forms available to merging tax partnerships and reveals how the different forms can affect the tax consequences of the parties to such a transaction. In particular, the article illustrates how parties should choose the proper form as needed to avoid adverse tax consequences and manage the bases of property and interests that they transfer or receive as part of a reorganization.

Number of Pages in PDF File: 5

Keywords: partnership merger, partnership division, partnership consolidation, LLC merger and division, assets-up merger, assets-over merger

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Date posted: January 3, 2014 ; Last revised: January 7, 2014

Suggested Citation

Borden, Bradley T. and O'Connor, Brian and Schneider, Steven R., Avoiding Adverse Tax Consequences in Partnership and LLC Reorganizations (December 20, 2013). Brooklyn Law School, Legal Studies Paper No. 363. Available at SSRN: http://ssrn.com/abstract=2374026 or http://dx.doi.org/10.2139/ssrn.2374026

Contact Information

Bradley T. Borden (Contact Author)
Brooklyn Law School ( email )
250 Joralemon Street
Brooklyn, NY 11201
United States

Brian O'Connor
Venable, LLP ( email )
United States
Steven R. Schneider
Miller & Chevalier ( email )
655 Fifteenth Street, N.W., Suite 900
Washington, DC 20005-5701
United States
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