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Pass-Through, Public Trading, and the Dubious Obstacle of Inside Basis Adjustments

45 Pages Posted: 16 May 2017 Last revised: 31 Aug 2017

Chris William Sanchirico

University of Pennsylvania Law School; University of Pennsylvania Wharton School - Business Economics and Public Policy Department

Date Written: May 16, 2017

Abstract

Elective “inside basis adjustments” are a central feature of partnership taxation, and their prospective infeasibility for publicly traded companies has played an important role in shaping leading corporate integration proposals. This paper questions whether such adjustments are necessary in the first place.

Web Appendix for "Pass-Through, Public Trading, and the Dubious Obstacle of Inside Basis Adjustments" available at:http://ssrn.com/abstract=2968859.

Keywords: partnership taxation, inside basis adjustments, corporate integration, realization, recognition, tax-timing, deferral

JEL Classification: K34, H25, H21

Suggested Citation

Sanchirico, Chris William, Pass-Through, Public Trading, and the Dubious Obstacle of Inside Basis Adjustments (May 16, 2017). Tax Law Review, Vol. 71, No. 4, 2018, Forthcoming; U of Penn, Inst for Law & Econ Research Paper No. 17-20. Available at SSRN: https://ssrn.com/abstract=2968794

Chris Sanchirico (Contact Author)

University of Pennsylvania Law School ( email )

3501 Sansom Street
Philadelphia, PA 19104
United States
215-898-4220 (Phone)

HOME PAGE: http://www.law.upenn.edu/faculty/csanchir/

University of Pennsylvania Wharton School - Business Economics and Public Policy Department

3641 Locust Walk
Philadelphia, PA 19104-6372
United States

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