Partnership formation, including but not limited to:

  • Characterizing various items as property;
  • Receipt of partnership interest in exchange for services;
  • Contract review for acquisition of partnership interests;
  • Drafting and creating thousands of entities that are taxed as partnerships for federal income tax purposes;
  • Advising on Section 83(b) and protective 83(b) elections;
  • Contribution of appreciated property and analyzing the three different 704(c) allocation methods (traditional, traditional with curative, remedial) as well as analyzing such methods for depreciable property;
  • Contributions of depreciable property;
  • Character of gains and losses from disposition of contributed property;
  • Contributions of encumbered property;
  • Contributions of accounts receivable and payable; and
  • Organization and syndication expenses.