Video Blog: Understanding Revenue Ruling 99-6, Situation 2
[Ed note:I’m aware that we planned to publish a video blog every Friday morning, but since we don’t expect many people to be working tomorrow, we’ve moved it up a day.]
Last week our video blog (or “vlog,” as one of my hip co-workers clarified the lexicon for me) focused on Situation 1 of Revenue Ruling 99-6,which provides the tax consequences upon the conversion of a multi-member partnership into a single member LLC disregardedas separate from its owner. Specifically, Situation 1 dealt with a fact pattern where one partner purchased the interests from the remaining partners, converting the partnership into a SMLLC.
Today we take on Situation 2 of Revenue Ruling 99-6, which again deals with the conversion of a multi-member partnership into a SMLLC, but this timeaddresses a fact pattern where an outside buyer purchases all thepartnership interests from the current members.
