Analyzing Fill-Up Allocations of Boot: The Implications Might Surprise You

摘要

When a fund engages in a like-kind exchange and some limited partners wish to "cash out" by redeeming their respective partnership interests, many practitioners entertain a "fill-up allocation " as a potential solution. This article explores the tax treatment of fill-up allocations in several like-kind exchange scenarios and illustrates why fill-up allocations may not have substantial economic effect in every context.