#partnerships
Partnership accounting, profit sharing, and financial management
Section 199A is now permanent under OBBBA. Pass-through owners get a 20% deduction, wider SSTB phase-in ranges ($75K single / $150K joint above the 2026 threshold), a new $400 minimum for material participants, and the same W-2 wage and UBIA tests at the top of the band.
Schedule M-1 reconciles book net income to taxable income on Forms 1120, 1120-S, and 1065.
Section 267 disallows losses on sales between related parties and defers deductions on accrued payments to related cash-basis payees. A practical guide to who counts as related, how constructive ownership works, the 267(d) gain offset, the 2.5-month payment safe harbor, and the bookkeeping habits that keep family businesses and partnerships audit-ready.
How Section 514 of the Internal Revenue Code taxes leveraged investments held by 501(c)(3) organizations, private foundations, and self-directed IRAs — including the debt/basis percentage calculation, Form 990-T mechanics, the 12-month look-back on sale, and the Section 514(c)(9) real estate exception for schools and pension trusts.
A Master Limited Partnership pays cash quarterly but issues a Schedule K-1, not a 1099. Most distributions reduce your cost basis instead of being taxed, holding units in an IRA can trigger UBTI and a Form 990-T once income exceeds $1,000, and selling converts depreciation into ordinary income under Section 751 — taxed up to 37%.
How individual MLP investors actually owe tax — UBTI on IRA-held units crosses the $1,000 Form 990-T threshold faster than expected, Section 751 reclassifies part of any sale gain as ordinary income, and the K-1's state schedule can force nonresident filings in operating states. Includes practical thresholds and basis-tracking rules.
Owner's equity is Assets minus Liabilities — the running total of contributions, draws, profit, and losses. This guide structures equity accounts for sole proprietors, partnerships, and LLCs, explains why draws are not expenses, and shows the year-end closing entries that keep a balance sheet in balance.
A disguised sale under Section 707(a)(2)(B) collapses a partnership contribution and a related cash distribution into a taxable sale. Transfers within two years are presumed a sale; the deemed-sale fraction equals consideration received divided by property FMV.
Section 707(a)(2)(B) recharacterizes paired property contributions and cash distributions to LLC members as taxable sales when they occur within two years. A walkthrough of the two-prong test, the rebuttable two-year presumption, the four regulatory exceptions, debt-financed distribution mechanics, and the Form 8275 disclosure that keeps partners out of audit trouble.
How partnerships and S corporations in 36+ states use the Pass-Through Entity Tax election under IRS Notice 2020-75 to deduct state income tax at the entity level and bypass the federal SALT cap — with a worked example, resident-credit mechanics, and 2026 election deadlines.
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
