White Paper

62 Pages
  • 62 Pages

The Allure and Illusion of Partners' Interests in a Partnership


Tax partnerships are quite popular for many reasons.

Unlike tax corporations, a tax partnership has favorable tax treatment and flexibile management. Partnership taxable income to through the partners who then report their own taxable income in their tax returns. The tax allocation rules of a partnership decides the partners' shares of the taxable income. This white paper reviews the allure and illusion to concepts of path dependency; and discusses three correlatives to end the myopia and improve tax allocation rules.



Bradley T Borden

Bradley T Borden

Brooklyn Law School

  • Professor of law at Brooklyn Law School
  • Advise, consult, and work as expert witness on matters related to partnership and real estate taxation
  • Have spoken at hundreds of seminars, conferences, and other professional gatherings on matters related to partnership and real estate taxation
  • Written over 100 articles in law reviews and professional journals related to partnership and real estate taxation
  • Wrote multiple books, including Taxation and Business Planning for Partnerships and LLCs (Aspen Publishers, 2017) and LLCs and Partnerships: Law, Finance, and Tax Planning (Wolters Kluwer, 2019)
  • Member, ABA Section of Taxation, NYSBA Tax Section, American Bar Foundation, American College of Tax Counsel
  • J.D. and LL.M. degrees, University of Florida; B.B.A. and M.B.A. degrees, Idaho State University
  • Can be contacted at 718-780-7550 or [email protected]

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