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.