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This course considers formation issues in the utilization of the partnership vehicle including issues regarding the allocation of nonrecourse liabilities and deductions attributable thereto, the use of special allocations, the tax consequences of contributing property with built-in gains and losses, the admission of a partner to an ongoing partnership, and the compensation and equity participation of partners. Additionally, issues involving exit strategies from a partnership are explored including the ¿758 election and the ¿¿734(b) and 743(b) adjustments, the application of ¿751(b), the maximization of capital gain treatment, and the effective use of ¿736. Finally, the course addresses the use of international tax partnerships and the uncertainty involved in the integration of Subchapter K and the international provisions. Tax treaty issues and entity classification issues, particularly respecting hybrid entities, are explored in depth. Prerequisite: Partnership Taxation