The article examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner

Die Up-or-out-Regel besagt, dass Assistenten in Partnerschaften (oder auch Universitäten) nach einer gewissen Zeit zu Partnern aufsteigen oder die Partnerschaft verlassen müssen. Eine dauerhafte Assistententätigkeit ist nicht möglich. Dies wirft die Frage auf, warum nicht Assistent bleiben...

Every business firm that is created must be categorized as some type of entity from the moment it begins to have value, either positive value or negative value. For many firms, the entity is simply a sole proprietorship. But if there is not a “sole” owner, then the entity must be something...

Introduction to partnership tax -- The passthrough system -- Introduction to partnership accounting -- Partnership allocations : general rules -- Partnership allocations : nonrecourse deductions -- Partnership allocations : special anti-income shifting rules -- Sales of partnership interests --...

For a partnership model with general type distributions and interdependent values, we derive the optimal dissolution mechanisms that, for arbitrary initial ownership, maximize any convex combination of revenue and social surplus. The solution involves ironing around typically interior worst-off...

The partnership taxation regime treats a partnership as simply a conduit (rather than a taxable entity) through which the profit (income) or loss of the partnership are passed onto partners, who will report it together with other profits (income) or losses on their income tax returns. By doing...

This paper analyses the efficiency of the Texas shootout and ½-auction partnership dissolution mechanisms when one of the partners has a chance to observe the other partner's valuation. The efficiency of the Texas shootout mechanism positively depends on the probability of such observation...

The statutory definition of a partnership is the “relation which subsists between persons carrying on a business in common with a view of profit”. Those persons could be natural persons, or other legal entities such as companies or trustees. However, a registered company under the Companies...

"Pass-through" businesses like partnerships and S-corporations now generate over half of U.S. business income and account for much of the post-1980 rise in the top- 1% income share. We use administrative tax data from 2011 to identify pass-through business owners and estimate how much tax they...

“Pass-through” businesses like partnerships and S-corporations now generate over half of U.S. business income and account for much of the post-1980 rise in the top- 1% income share. We use administrative tax data from 2011 to identify pass-through business owners and estimate how much tax...

Professional service firms (PSFs) such as accounting firms, management consultancies, or advertising agencies use very different forms of governance ranging from traditional professional partnerships to public corporations. In spite of the extensive literature, little academic work has been done...

This paper studies the effect of business partners on the commercialization of nvention based ventures, and it assesses the relative importance of partners' human and social capital on commercialization outcomes. Projects run by partnerships were five times more likely to reach...

This paper studies the effect of business partners on the commercialization of invention-based ventures, and it assesses the relative importance of the complementary skills, contacts, and financial capital that these partners may add to the original inventor-entrepreneur. Projects run by...

We investigate an informal yet important mechanism in the private equity industry that helps to reduce uncertainty: relationship building. Based on a large sample of private equity funds over the 1980-2010 period, we find that the general partners strategically allocate good funds to loyal...

Section 704(c)(1)(A) governs the taxation of unrealized appreciation and loss in property contributed to a partnership. The principles underlying §704(c)(1)(A) also apply to property held by a partnership when additional property is contributed to the venture or existing property is distributed...

This paper studies the effect of business partners on the commercialization of nvention based ventures, and it assesses the relative importance of partners' human and social capital on commercialization outcomes. Projects run by partnerships were five times more likely to reach...

The passthrough system -- Introduction to partnership accounting -- Partnership allocations : general rules -- Partnership allocations : nonrecourse deductions -- Partnership allocations : special anti-income shifting rules -- Sales of partnership interests -- Property contributions and...

Professional service firms (PSFs) such as accounting firms, management consultancies, or advertising agencies use very different forms of governance ranging from traditional professional partnerships to public corporations. In spite of the extensive literature, little academic work has been done...

A detailed road map for wealth managers who want to build an ensemble firm or team and achieve sustained growth, profitability and high valuations Why do ten percent of wealth management firms grow faster than the rest of the industry, often despite the turbulence of the markets? The answer,...

We study a partnership that anticipates its possible dissolution. In our model, partnerships form in order to take advantage of complementary skills; although new opportunities may arise that make partners ̕skills useless. We characterize the optimal, incentive-compatible partnership contract...