When should the election to be excluded from the partnership tax provisions be made?

Article Abstract:

Electing out of the rules of Subchapter K can sometimes help partnerships gain improved flexibility in reporting losses and profits from jointly owned properties. There are no set rules as to when election should be made to be excluded from Subchapter K. Each eligible partnership should have the tax advisor review separately the impact of the election, based on the unique circumstances and facts of the partnership. Tax accounting, contributions, limitations on losses, termination of existing partnerships, and partnership elections are discussed.

Election (Wills)

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Partnership liabilities and allocations are subjects of new Regulations

Article Abstract:

IRS Temporary Regulations affecting taxation of partnerships and partners are discussed. Economic risk of loss analysis to determine recourse and nonrecourse partnership liabilities under the Regulations is described and illustrated, and new treatment of minimum gain chargeback and tiered partnerships is reviewed.

Management, Liabilities (Accounting), Laws, regulations and rules, United States. Internal Revenue Service

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Contributing mortgaged property to a partnership may provide tax savings

Article Abstract:

Contributions of property to a partnership are generally tax free, but may be taxable in certain situations. Distinctions between sales and contributions are discussed, and strategies for avoiding recognition of gain are presented.

Mortgages

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