Oleg Polyatskiy authors Tax Notes article, A Guide for Corporate Groups on Structuring Tax-Efficient Partnership Terminations

This two-part article is designed to be a guide for corporate groups on structuring a tax-efficient partnership termination. Part 1 begins with a high-level overview of the issues and potential solutions to consider when structuring a partnership termination, and then describes common transactions that corporate groups use to terminate partnerships. The remainder of part 1 and all of part 2 analyze in detail the tax rules that may trigger gain recognition upon a partnership termination and the planning techniques that can eliminate or reduce that gain.