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Regulation-Pships

Partnership taxation

QuestionAnswer
Pship inception fees deductible up to 5k with the rest amortized over 180 mos, if total over 50k the deduction reduced dollar for dollar above the 50 k limit
Pship fees to prepre representation in offering materials considered SYNDICATION fees and can not be amortized or depreciated (only capitalized)
Pship interest received as compensation taxable to partner as ordinary in proportion to the FMV of the pship value
Pship inception contribution has no gain or loss except 3 situations performed svsc, property had mrtg in excess of basis, had 1245 or 1250 recapture
Pship income & loss calc items with special tax characteristics separated ( items with partial/full exclusion, dollar/percentage limitation, etc) all remaining, that are ORDINARY in nature netted for pship distributable income
Pship loss limitations pship loss is last event in taxable year and limit loss to basis with excess CF, at-risk limitation, passive loss lims (lim partner fails active participation test, to qual for 25k exception in RE a partner must own at least 10% of the pship value).
Pship agrments relative to contributed property is property is subsequently sold, the gain is first allocated to the contributing partner up to the FMV of pship interest at the date of contribution, then excess gain allocated to other partners.
Family pship partner svsc reasonable compensation for services must be deducted before allocation of pship income based on partner interest.
Personal asset of a partner sold to pship to be held as investment capital asset with the gain on the sale as capital to the partner.  If the sold asset is capital to pship then gain is capital to seller
Pship year end under IRC 444 pship MUST choose tax year where the deferral period is <3 mos
Pship termination sale/exchange of >50% within 12mos terminates the pship, due to this termination if members cont. ops., DEEMED distrib. of assets to partners&purchaser &HYPOTHETICAL re-contribution to NEW Pship, DEATH NOT terminate pship if estate participates in profits
Pship interest sale treated as capital asset, if cash and relief of liabilities received, gain=cash+liabilities-basis UNLESS pship had appreciated inventory OR unrealized receivables, proportionate share is ORDINARY
Non liquidating distribution of property with basis in excess of receiving partner's basis limited to the receiving partners basis, generally, NO gain/loss recognized on non-liquidating property distributions unless all cash, then gain in excess of partner's basis
Retired partner pmnts determined by pship income considered distributive share of the retired partner and are ORDINARY income.
Created by: baurjan on 2011-11-14



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