Although the general rule aims to treat partnership distributions as nontaxable events, the exceptions can quickly overshadow the general rule.The possibility of moving property in and out of partnerships unimpeded by possible negative tax considerations to the partners creates the potential for abuse.Each chapter in this Audit Techniques Guide (ATG) can be printed individually.Please follow the links at the beginning or end of this chapter to return to either the previous chapter or the Table of Contents or to proceed to the next chapter.
To prevent income or basis shifting among partners, several provisions track property movements.
On the other hand, a liquidating distribution completely terminates the partner’s interest in the partnership.
LMSB-04-1107-076 Revised 12/2007 NOTE: This guide is current through the publication date.
Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.
INTRODUCTION As a general rule, when a partner transfers property to a partnership, gain or loss is not recognized.
Additionally, a partner does not generally recognize gain or loss upon receiving distributions from a partnership unless the distribution is a cash distribution in excess of the partner’s basis in his/her partnership interest (outside basis).