Interrelationships of Sections 731, 736, and 751: A Worksheet Approach.
本文针对合伙企业清算分配中涉及现金支付时,如何正确适用美国税法第731、736和751条的顺序问题,提出了一种工作表方法,帮助税务从业者简化复杂决策过程并减少错误。
Abstract It is clear from the statutes that most distributions in liquidation of a partnership interest that involve some cash payments are subject to the provisions of three Code sections: Sections 731, 736, and 751. It is critical to understand in what sequence the provisions of all three sections are applicable. To facilitate the proper use of the intricate rules, the authors have developed a worksheet approach that is designed to apply the appropriate provisions in their correct sequence. Initially, this approach may require a considerable start-up effort. However, once the concepts have been mastered, the worksheet becomes an indispensable tool that converts a difficult and tedious task to a programmed decision process which simplifies the task, eliminates errors, and may be adaptable to the computer.