Avoiding Adverse Tax Consequences in Partnership and LLC Reorganizations
Bradley T. Borden
Brooklyn Law School
Steven R. Schneider
Miller & Chevalier
December 20, 2013
Brooklyn Law School, Legal Studies Paper No. 363
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
Date posted: January 3, 2014 ; Last revised: January 7, 2014
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