The EU and Greenland are taking their unique partnership forward. President von der Leyen has inaugurated the EU Office in Nuuk and signed agreements totalling almost €94 million under the EU Global Gateway investment plan: €71.25 million for education and skills and €22.5 million for...

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...

Professional service firms are common in some areas, in particular auditing and law. They are organized as partnerships, private corporations, or public corporations. This paper mainly discusses the first one of these three. When a partner leaves the partnership, her/his shares are redeemed. Two...

Consider a partnership consisting of two symmetrically informed parties who may each own a share of an asset. It is ex post efficient that tomorrow the party with the larger valuation gets the asset. Yet, today the parties can make investments to enhance the asset's productivity. Contracts are...

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 law of the United States takes two fundamentally different approaches to taxing business income. The income of many corporations is taxed to the corporation when earned and again to the shareholders when corporate profits are distributed to them. In contrast, the income of most corporations,...

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...

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 --...

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...

"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...

We assess comprehensively how incomes, employment, housing, mental health and life satisfaction change following a partnership dissolution, using data from 18 waves of BHPS. We confirm that women and children see living standards decline by more than men, on average, upon separation, but find...

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...

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...

This paper investigates the early development of English cotton spinning by analyzing about 700 bankruptcies and 1300 dissolutions of partnership reported in the London Gazette, 1770-1840. The data show two temporal cycles, peaking in the early to mid-1800s and in the later 1820s, near the ends...

This Article presents a theory of partnership taxation. To provide context for the presentation, the Article examines the history and status of partnerships. That examination reveals humans have a natural tendency to form partnerships and partnerships create a significant challenge for...

Partnerships form and dissolve. Dissolution often requires a change in property rights, from joint to single ownership, in the hands of one of the partners. This calls for a dissolution rule that assigns full property rights to the partner who makes the best use of these assets, and assures fair...

Past work has shown that asymmetric information and asymmetric ownership affect the possibility of efficient dissolution of partnerships. We show that \textit{control} is also a central determinant of the possibility of efficient implementation. We demonstrate this point by analyzing a benchmark...