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Partnership Taxation - Substantiality Tests  

CATEGORY: Taxation
  Online & Mobile
1 CPE Credits

Whether the economic effect of an allocation is substantial does not depend on the magnitude of the economic effect, but on whether there is a real economic effect on the partners aside from the tax consequences of the allocation. The substantiality test is designed to insure that the economic effects of an allocation do not arise principally from the tax character of an allocated partnership item, and the differing tax impact on the partners which may result.

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