IRC section 704(b) that severely restricted the amount of flexibility that partnerships enjoyed over However, given a tax rate of less than 100%, partners that received cash could Stephen G. Utz,Partnership Taxation in Transition: Of Form, Substance, and Economic Risk, 43 TaxHaden, Ed R...
Instead, these partnerships would allocate all IRC Section 163(j) items in step 2 proportionately. The Final Regulations also confirm that allocations pursuant to the 11-step process satisfy the requirements of IRC Section 704(b). Specifically, Treas. Reg. Section 1.704-1(b)(4)(xi...
OBJECTIVE/PERCEIVED VS. ENACTED ENVIRONMENT Objective & Perceived Enacted (Interpretative worldview) Environment Independently given Accurately /inaccurately perceived Enacted through social construction and interaction processes of organized actors Interpretative: Specific set of events and relationships noticed and...