Tax Planning partner Sheldon Banoff will present "Partnership-to-Partner (Non?-)Attribution of Activities, Trade or Business, Motive, Intent and Purpose: Is There a 'Theory of Everything'?" at 8:30 a.m. on Saturday, November 7. The panel will focus on the following questions:
- Should the activities, trade or business status, motive, intent, or purpose of a partnership be attributed to its partners for tax purposes?
- If so, when and why?
- If attribution is appropriate, should the attribution be to all partners, or only some?
- If attribution is made only to some partners, which ones?
- Is there a central theory––or series of theorems––to give guidance as to when attribution of the five categories from the partnership to all or some of its partners is appropriate in order to predict when the IRS or the courts will or will not apply such attribution?
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