Partnerships making guaranteed payments may want to consider restructuring them as priority profit allocations.
Contributions, Distributions & Basis
A taxpayer, who received interests in four partnerships from his father by gift or bequest, did not step into his father’s shoes with respect to interest on certain partnership loans,
The IRS agreed with the team’s position that the amounts received for the memberships do not constitute income because the team is obligated to repay the money to the “members.”
This discussion focuses on the withholding regime under the proposed regulations applicable to non-publicly traded partnerships and highlights a number of compliance and practical implications.
The proposed regulations provided much-anticipated rules for RICs with REIT income for purposes of Sec. 199A.
Aggregation may allow a taxpayer to claim a greater QBI deduction than if the wages and capital limitation was applied separately.
This article explains the tax implications of owning and selling an interest in a publicly traded partnership treated as a partnership and the tax reporting and compliance challenges that an investor in a PTP may face.
A note contributed to a partnership by an individual in exchange for an interest in the partnership was a bona fide debt.
Treasury never finalized the bulk of the regulations implementing Sec. 465, so reliance on proposed regulations issued in 1979 is the norm.
This article reviews and analyzes recent rulings and decisions involving partnerships and discusses developments in partnership formation, debt and income allocations, distributions, and basis adjustments.
The IRS concluded that a taxpayer was not permitted to aggregate the S corporations with the partnership for the purpose of applying the at-risk rules of Sec. 465.
This article discusses who qualifies to take the credit, how to make the election, the calculation and allocation of the credit, and how to report it.
Depending on how a taxpayer’s ownership is structured, the sale of a partnership interest can have a Sec. 280G impact on partners or members that are C corporations.
Lender Management contended that its activities met the test for an active trade or business under guidelines.
This discussion gives a historical perspective of the treatment of the sale of a partnership interest and the changes enacted as part of the TCJA.
The IRS announced that it was withdrawing temporary regulations on the treatment of partnership liabilities for disguised-sale purposes and proposing to reinstate the old rules.
The IRS announced that S corporations are subject to the new extended three-year holding period applicable to carried interests.
The new deduction allows certain business owners to keep pace with the significant corporate tax cut provided by the Tax Cuts and Jobs Act.
A partner’s basis is key to determining the application of loss limitations and the recognition of gain or loss on partnership distributions and dispositions of partnership interests.
Publicly traded partnerships can present challenges for reporting.