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LLC

LLC formation, taxation, and accounting best practices explained

Section 469 Passive Activity Grouping: How Real Estate Investors Unlock Suspended Losses

How real estate investors and multi-entity owners use the Section 469 grouping election under Reg 1.469-4 to aggregate hours across properties and release suspended losses — covering the appropriate economic unit test, the Reg 1.469-9(g) real estate professional aggregation, Rev. Proc. 2010-13 disclosure rules, and why the election is easier to file than to undo.

Section 754 Election and 743(b) Basis Adjustments: How Partnerships Step Up Inside Basis When a Partner Buys In or Dies

A Section 754 election triggers a 743(b) inside-basis step-up when a partner dies, sells, or is bought in — preventing heirs and incoming partners from paying tax twice on the same appreciation. This guide covers 743(b) and 734(b) mechanics, Section 755 allocation across asset classes, the substantial built-in loss rule, Form 15254 revocation, and when the administrative cost outweighs the benefit.

The BBA Partnership Audit Playbook: Partnership Representatives, Push-Out Elections, and the Imputed Underpayment Trap You Did Not See Coming

Under the Bipartisan Budget Act centralized audit regime, the IRS assesses partnership tax adjustments at the entity level at the highest individual rate. This guide explains when to elect out under Section 6221(b), how the partnership representative can modify or push out the imputed underpayment under Section 6226, and how to file an administrative adjustment request on Form 8082.