Tax Notes has published an article that discusses a recent conclusion drawn by the Internal Revenue Service in partially redacted program manager technical assistance. The IRS addressed the temporary pooling of funds on a non-pro-rata basis and the appointment of a tenant-in-common (TIC) owner as a payment or communications agent due to the bankruptcy of the master tenant, concluding that if the TIC arrangements were not partnerships for income tax purposes before the pooling of funds and the appointment of a TIC owner, then such actions would not cause the TIC owners to become partners for income tax purposes.
See Tax Analysts, "IRS Addresses Tenant-In-Common Structures With Bankrupt Master Tenants." 2010 TNT 91-15, May 12, 2010
Posted by Joshua Hock, Associate Editor, Wealth Strategies Journal
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