Distributions to retiring partners

The combined effect of the changes to the partnership distribution rules and the amortization of intangibles by the Revenue Reconciliation Act of 1993 (RRA) creates complex tax problems. The RRA included several provisions that modify the tax treatment of distributions to retiring or deceased partne...

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Bibliographic Details
Published in:The Tax Adviser 1994-05, Vol.25 (5), p.305
Main Authors: Jamison, Robert W, Boyd, James H
Format: Magazinearticle
Language:English
Subjects:
Accounting and auditing
Amortization
Asset acquisitions
Disposition of partnerships
Distribution of partnership interests
Going concerns
Goodwill
Goodwill (Business)
Intangible assets
Internal Revenue Code
Laws, regulations and rules
Partnership
Partnership distributions
Partnership interest
Section 197
Section 736
Taxation
Taxpayers
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Summary:The combined effect of the changes to the partnership distribution rules and the amortization of intangibles by the Revenue Reconciliation Act of 1993 (RRA) creates complex tax problems. The RRA included several provisions that modify the tax treatment of distributions to retiring or deceased partners under Sec. 736. In general, retiring partners who receive cash distributions in liquidation of partnership interests will not be adversely affected by, and may even benefit from, the changes in the law. The new rules relating to intangible assets provide definite benefits for many taxpayers, since goodwill is now amortizable over a 15-year period. The new amortization rules apply to all intangible assets acquired in the acquisition of a going business. These assets are specifically defined in Sec. 197(d).
ISSN:0039-9957