Question
Bill and Tom each own 15% of both capital and profits of BTW Partnership, which has a calendar tax year. They sell their entire interests
Bill and Tom each own 15% of both capital and profits of BTW Partnership, which has a calendar tax year. They sell their entire interests to Jill, a new partner, on May 15 of the current calendar year. Dan, another BTW partner, owns 20% of both capital and profits and sells his entire interest to Ken, a new partner, on March 10 of the next year. Does BTW terminate due to these events and why? If so, on what date does it terminate?
a) Yes, BTW terminates as 30% was sold during the partnership tax year.
b) No, BTW does not terminate since only 30% was sold on a single date.
c) No, BTW does not terminate as the TCJA repealed technical terminations for tax years
beginning after December 31, 2017.
d) Yes, BTW terminates on March 10 of the next year because more than 50% was sold
during a 12-month period.
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