Table Of Content

Index to Volume 8 Author Index BELL, WILLIAM W. & SHOEMAKER, DAVID B., International Developments: Foreign Direct Investment in U.S. Real Estate: The Screws Tighten 258 374 JOURNAL OF PARTNERSHIP TAXATION BRENMAN, LAWRENCE H., Amended Temporary Passive Loss Regulations Clarify Developer Rule, but Problems Remain Tax-Oriented Investments: An Exit Strategy for Partners: Aban- donment of Partnership Interests A Lesson in Fractions: How to Attract Capital From Tax-Exempt Investors CARMAN, WILLIAM T. & DANCE, GLENN E., Accounting Issues: Even Charitable Contributions by Partnerships Can Be Complex! 80 Failure to Pay the Piper Can Accelerate a Requirement to Pay Uncle Sam CARMAN, WILLIAM T. & ZOOT, JORDAN, Accounting Issues: Having Tax-Exempt Partners Can Be a Taxing Proposition COMITER, RICHARD B. & LOONEY, STEPHEN R., S Corpora- tions: Uncertain Application of the Statute of Limitations to § Corpora- tions and Their Shareholders CUFF, TERENCE F., Proper Drafting Can Resolve Problems Created by the Minimum Gain Chargeback CULLINS, JOHN W., MILLER, NANCY L. & MONTGOMERY, STEVE, Washington Tax Watch: Treasury Revises Liability Allocation Rules GRACE, MICHAEL J., Self-Charged Interest Regulations Ease Con- sequences of Partner-Partnership Loans HART, KENNETH M., Partnership Agreements That Cope With Restoration of Deficit Capital Accounts LOSEY, F. RICHARD, Recent Cases and Rulings 87, 182, 346 MARCHBANKS, MICHAEL, How Should Dual Capacity Partners Be Treated for Income Tax Purposes? ............c00eeeeeee 146 MARK, RICHARD S. & ROBISON, JACK, Numerous Options Exist for Specially Allocating Depletion, but Which Is Best?......... 329 MONTGOMERY, STEVE & BOBROW, RICHARD S., Washington Tax Watch: K-1 Simplification Partnership Audit and Administration Proposals PURINTUN, ANN-ELIZABETH, Partnership Procedure: FPAA Valid Despite Untimely Commencement Notice REEVES, RON L. & SHAPLEIGH, COLBERT C., Effect of Dis- charge of Indebtedness Income on Partnerships and Partners .. . RUBIN, BLAKE D. & CAVANAGH, RITA A., Guidelines for Using a Partnership Freeze to Reduce Corporate Taxes: Part II SANSWEET, JEFFREY B., Selecting the Most Favorable Retirement Plan for a Service Partnership SCHOENBRUN, GARY L., Consequences of Preferred Return Provi- sions in a Partnership Agreement INDEX TO VOLUME 8 SMILEY, STAFFORD, Dispositions of U.S. Partnership Interests by Nonresident Aliens SNOW, GERALD T., Family Partnership Rules Add Complexity to Partnership Allocations STOLBACH, GARY, WALLACE, TODD & EVAUL, DAVID, New Estate Freeze Rules: Gift Leveraging Can Achieve Estate Planning Objectives New Estate Freeze Rules: Practical Issues for Gift Leveraging .. TOUSEY, CLAY B., JR. & WALLIS, DONALD W., Estate Planning: Availability of Section 754 Election Is an Important Consideration in Estate Planning for Owners of Closely Held Businesses 93 The Effect of Death of a Partner on the Continuing Existence of the Partnership for Tax Purposes 283 Title Index Accounting Issues, William T. Carman & Glenn E. Dance: Even Charitable Contributions by Partnerships Can Be Complex! Failure to Pay the Piper Can Accelerate a Requirement to Pay Accounting Issues, William T. Carman & Jordan S. Zoot: Having Tax-Exempt Partners Can Be a Taxing Proposition Amended Temporary Passive Loss Regulations Clarify Developer Rule, but Problems Remain, Lawrence H. Brenman Consequences of Preferred Return Provisions in a Partnership Agree- ment, Gary L. Schoenbrun Dispositions of U.S. Partnership Interests by Nonresident Aliens, Stafford Smiley Effect of Discharge of Indebtedness Income on Partnerships and Partners, Ron L. Reeves & Colbert C. Shapleigh Estate Planning, Clay B. Tousey, Jr. & Donald W. Wallis: Availability of Section 754 Election Is an Important Consideration in Estate Planning for Owners of Closely Held Businesses The Effect of Death of a Partner on the Continuing Existence of the Partnership for Tax Purposes Family Partnership Rules Add Complexity to Partnership Allocations, Gerald T. Snow Guidelines for Using a Partnership Freeze to Reduce Corporate Taxes: Part II, Blake D. Rubin & Rita A. Cavanagh How Should Dual Capacity Partners Be Treated for Income Tax Purposes? Michael L. Marchbanks International Developments, William W. Bell & David B. Shoemaker: Foreign Direct Investment in U.S. Real Estate: The Screws Tighten 376 JOURNAL OF PARTNERSHIP TAXATION New Estate Freeze Rules: Gift Leveraging Can Achieve Estate Planning Objectives, Gary Stolbach, Todd Wallace & David Evaul New Estate Freeze Rules: Practical Issues for Gift Leveraging, Gary Stolbach, Todd Wallace & David Evaul Numerous Options Exist for Specially Allocating Depletion, but Which Is Best?, Richard S. Mark & Jack Robison Partnership Agreements That Cope With Restoration of Deficit Capital Accounts, Kenneth M. Hart Partnership Procedure, Ann-Elizabeth Purintun: FPAA Valid Despite Untimely Commencement Notice Proper Drafting Can Resolve Problems Created by the Minimum Gain Chargeback, Terence F. Cuff Recent Cases and Rulings, F. Richard Losey S Corporations, Richard B. Comiter & Stephen R. Looney: Uncertain Application of the Statute of Limitations to S Corpora- tions and Their Shareholders Selecting the Most Favorable Retirement Plan for a Service Partnership, Jeffrey B. Sansweet Self-Charged Interest Regulations Ease Consequences of Partner-Part- nership Loans, Michael J. Grace Tax-Oriented Investments, Lawrence H. Brenman: An Exit Strategy for Partners: Abandonment of Partnership Interests A Lesson in Fractions: How to Attract Capital From Tax-Exempt Investors Washington Tax Watch, John W. Cullins, Nancy L. Miller & Steve Montgomery: Treasury Revises Liability Allocation Rules Washington Tax Watch, Steve Montgomery & Richard S. Bobrow: K-1 Simplification Partnership Audit and Administration Proposals wee