Rethinking Book-Tax Disparities and Partnership Distributions
Tax Notes Federal, Vol. 170, p. 711, (Feb. 1, 2021)
19 Pages Posted: 29 Apr 2021
Date Written: April 28, 2021
This article examines the “tax-follows-book” principle through the lens of partnership distributions of property with reverse section 704(c) items and details ways the law could ensure that post-distribution allocations of tax items follow pre-distribution allocations of book items.
Keywords: partnership distribution, section 704(c), section 751
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