Allocations of Liabilities into Outside Basis, including but not limited to:

  • Analyzing recourse versus nonrecouse nature of debt;
  • Analyzing economic risk of loss for recourse debt;
  • Allocating nonrecourse debt and deductions;
  • Tracking Tufts minimum gain;
  • Analyzing debt shifts under 752 and determining whether such debt shift triggers a gain;
  • Converting limited liability companies into limited partnerships and vice versa and reviewing debt shifts thereto; and
  • Allocating recourse debt, and shifting recourse debt to other partners for loss purposes.