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PARTNERSHIP PARTY POOPER
February 28, 2006
Tax Law Professor Darryll K. Jones wants to remove the punchbowl from the partnership party ($):
By allowing partnerships to divide tax benefits and burdens in a manner disproportionate to relative ownership, subchapter K turns Horst on its head. Why should that be the case? Why should we measure partnership tax benefits and burdens so differently from individuals or shareholders, and indeed in a manner that makes no economic sense? Let's look at the history of special allocations before articulating what has become a virtually meaningless, yet rote, justification for the current state of affairs.
Why? So we can have 15 pages of tax verbiage in every partnership agreement, of course! The TaxProf Blog links to Mr. Jones's piece today.
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