I am working on a paper for my Advanced Partnership Taxation course. Please define/explain in detail the following:

-If a partnership agreement contains special allocations that do not have substantial economic effect, what are the consequences?

-Please discuss the different ways a payment to a retiring partner may be treated.

-Discuss a situation in which a partner could recognize gain on a partnership distribution even if no cash is distributed to the partner.

-For a special allocation of partnership items among the partners to be respected by the IRS, the special allocation must have substantial economic effect. Please explain how a partnership can meet the “economic effect” portion of the substantial economic effect requirement.

-Explain how a partnership would fail the “substantiality” portion of the substantial economic effect requirement.

-The substantial economic effect requirement will nevertheless be met for nonrecourse deductions if the partnership agreement contains a minimum gain chargeback. Explain generally what a minimum gain chargeback is.

-Define a Section 754 election. What does a Section 754 election allow a partnership to do?

-What does “QIO” stand for in the context of economic effect? Explain what a QIO provision causes the partnership to do. Why would members of an LLC be particularly interested in a QIO as opposed to the alternative under the general test for economic effect? -Regarding the “substantiality” prong of the substantial economic effect test, explain what “shifting” tax consequences are and what “transitory” allocations are.