Assertion: partnership's partner | /r/CapableOf | contribute service
Facets:
value: for a profits interest
type: PURPOSE
value: for capital interest in the partnership
type: PURPOSE
Source sentences:
text: If a partner contributes services for capital interest in the partnership, then that interest is taxable, should it be subject to ready valuation.
text: If a partner contributes services for a profits interest, then that interest is not taxable upon the date of the exchange because any valuation would be too speculative unless it is for an asset that has low risk and a guaranteed return like a Treasury bill or the partner sells that interest within two years of the exchange.
text: Recently the Treasury proposed a safe harbor valuation procedure whereby a "service provider" (a partner who contributes services for a partnership interest) may be taxed on the valuation of the fair market value of the liquidation value of the property received.