John Reyna -Freeman Law, Texas

The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly created firm.[1]  Thus, no gain is recognized to a partnership or to any of its partners because of a contribution of property to the partnership in exchange for an interest in the partnership.[2] While this nonrecognition rule is a useful instrument in the tax practitioner’s toolbox, the rule’s glamor often overshadows an important exception. Under I.R.C. § 721(b), the general nonrecognition rule will not apply to gain realized on a transfer of property to a partnership that would be treated as an investment company (within the meaning of I.R.C. § 351) if the partnership were incorporated.[3]

This reference to I.R.C. § 351 shifts the analysis to the transfer rules for corporations to determine if the transferee partnership qualifies as an investment company (i.e., an investment partnership). Under the Treasury Regulations, a transfer of property to an investment partnership occurs when:

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TaxConnections is conducting a search for an investment firm to fill a Tax Manager role located in San Francisco, CA. We would genuinely appreciate your review of this opportunity and kindly refer this to anyone who may appreciate learning more.

The Tax Manager will be responsible for assisting senior tax management with tax research and planning and all aspects of the tax compliance and forecasting for a very significant investment partnership and the related investment management entity. Individual must have a solid understanding of current tax laws including knowledge of investment partnership structures.

Researching and communicating the tax consequences of current and proposed investments will be a part of the responsibilities of the successful candidate. In addition, the position will require both the preparation and review of highly detailed complex Federal, California and multi-state income tax returns, foreign investment reporting implications, preparation of tax forecasts and researching complex tax issues.  The Tax Manager must be able to perform multiple tasks, have proven project management skills and produce high quality, accurate and detailed work on a timely basis. Also, must be able to timely identify and communicate issues, positions, and opportunities both orally and in writing to management.

Responsibilities include the following:
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