From the editor

This issue of Business Entities features articles that we are convinced will be of great interest to our readers. We lead off with an article by Scott Smith, a member of our Board of Editors, and Sharlene Amitay on the state income tax treatment of selling a joint venture interest. While for federal income tax purposes, the sale of an interest in an entity taxable as a partnership will generate taxable gain or loss, the state tax treatment of the same transaction can vary, depending on the type of entity or interest being sold, the relationship between the seller and the entity, and the rules of the taxing state. The article reviews state sourcing and apportionment rules for assigning gains and losses from the sale of joint venture interests and talks about the Supreme Court's decision in Allied-Signal where a partnership was engaged in business operations in more than one state.

Last October the Treasury issued revised temporary regulations for tax shelter registration and list maintenance. These revised regulations modified and expanded the types of transactions and persons subject to the registration and list maintenance requirements. The revised temporary regulations define a "reportable transaction" as one that falls in any one of six categories, instead of the "listed transaction" or "2 out...