Technical accounting research memo

I chose Accounting because I could not fin TAX----To do this memo the writer has to be some knowledge about TAX since it is required some citation from "ATTACHED SOURCES"--PLEASE follow the instructions, template, and also I included a MEMO EXAMPLE .

Please do not hesitate to let me know if you can do the work as required.

**YOU SHOULD DOCUMENT YOUR MEMO WITH APPROPRIATE CITATIONS TO CODE SECTIONS, REGULATIONS (REG.), REVENUE RULINGS (REV. RUL.), REVENUE PROCEDURES (REV. PROC.), PRIVATE LETTER RULING (PLR) RECOGNIZED TAX TREATISES (FROM RIA CHECKPOINT). YOU MAY REFERENCE TAX RESEARCH TOOLS (SUCH AS RIA CHECKPOINT) AND TAX ARTICLES (SUCH AS FROM THE TAX ADVISOR).Partnership Tax Memorandum June 12, 2017 TO: Prof. Martin Scheckner, CPA, MAcc (Taxation), CFP, CFE FROM: Gabriela Casanova RE: Partnership Tax Memorandum (ACG 4011-U01) The Internal Revenue Code identifies two types of partnership terminations under § 708; an actual termination and a technical termination. Under I.R.C. § 708(b)(1)(B), a technical termination occurs when “within a 12-month period, there is a sale or exchange of 50% or more of the total interest in partnership capital and profits.” Unlike an actual termination, a partnership does not cease to exist as a partnership or in its totality under a technical termination. Also, the technical termination of a partnership can take the form of one sale or it could be composed of several sales of interest. Disposing of interests through gifts, bequests or inheritance, contribution of property, and liquidation of partnership interests does not constitute a sale or exchange and as such does not trigger a technical termination (I.R.C. § 1.708-1(b)(2)). For tax purposes, a technical termination encompasses two transactions. As outlined in I.R.C. § 1.708-1(b)(4), in a technical termination: 1. “the partnership contributes all of its assets and liabilities to a new partnership in exchange for an interest in the new partnership…” 2. “… and, immediately thereafter, the terminated partnership distributes interests in the new partnership to the purchasing partner and the other remaining partners in proportion to their respective interests in the terminated partnership in liquidation of the terminated partnership…” In a technical termination, partners’ interests in the terminated partnership are ‘zeroed out’ and as such, the technically terminated partnership has a momentary 100% interest in the partnership (Williford and Sinnett). Additionally, continuing partners’ interests in the new partnership will be equivalent to their share of interest in the terminated partnership. Furthermore, the basis of assets and liabilities contributed by the terminated partnership to the new partnership remains unchanged. Nonetheless, if the terminated partnership makes a Section 754 election, the basis of assets is adjusted to reflect the election, with § 734(b) or § 743(b) adjustments, and such basis carries forward to the new partnership. Noting the new partnership is allowed to make new G.M.C. 1 06/12/2017 Partnership Tax Memorandum June 12, 2017 accounting method elections, it is thus allowed to make a Section 754 election as well. As indicated in I.R.C. § 1.754-1(b)(1), a partnership elects a Section 754 election in a written statement filed with the partnership return for the taxable year in which assets are transferred. In addition, the holding period of assets from the terminated partnership transfers to the new partnership (I.R.C. § 735(b)). Tangible assets transferred to the new partnership are treated as if they were disposed of by the terminated partnership and the new partnership treats assets transferred as though they were purchased. Depreciation restarts with regards to assets transferred.