The U.S. IRS has released an international practice unit on the Sale of a Partnership Interest. The issue and transaction overview of the practice unit includes the following:
- When a sale of a partnership interest occurs, the entity theory is the underlying concept, not the aggregate theory. This means the ownership interest a partner has in a partnership is treated as a separate asset that can be purchased and sold.
- The general rule is the selling partner treats the gain or loss on the sa…