Unitizations:

  • Unitization where parties elect out of Subchapter K:
    • Unitization agreement;
    • Like kind exchange treatment;
    • Character of gain or loss;
    • Re-characterization rule;
    • Computational rules; and
    • Basis allocation
  • Unitization treated as partnerships:
    • Taxable exchange of partnership interests;
    • Transfer of property in the formation of a partnership;
    • Basis in partnership interest;
    • Partnership’s basis in the properties;
    • Character of gain to the partner; and
    • Remaining recapture potential.