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#partnerships

Partnerships

Partnership accounting, profit sharing, and financial management

Low-Income Housing Tax Credit (LIHTC) Section 42: How Developers Use 9% and 4% Credits to Finance Affordable Housing Projects

A 2026 LIHTC field guide for developers — how the 9% and 4% credits differ, how qualified basis and the 70%/30% present-value subsidies are calculated, the three overlapping compliance clocks, the IRS forms (8609, 8609-A, 8586, 8611), syndication mechanics, and the One Big Beautiful Bill Act changes that cut the bond financing test from 50% to 25%.

Section 47 Historic Tax Credit: A 2026 Field Guide for Developers and Their CPAs

Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.

First-Time Penalty Abatement Goes Automatic in 2026: Clean-Compliance IRS Relief for Failure-to-File, Pay, and Deposit Penalties

Starting filing season 2026, the IRS will apply First-Time Penalty Abatement automatically for taxpayers with a clean three-year compliance record — wiping Failure-to-File, Failure-to-Pay, and Failure-to-Deposit penalties without a phone call or Form 843. Here is how the rollout works, who qualifies, and when reasonable cause is the smarter move.

Section 162(m) and the $1 Million Cap: Why Your Covered Employee List Is About to Get a Lot Longer in 2026

Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.

Section 754 Election: How Partnerships Use Inside Basis Step-Ups to Save Incoming Partners and Heirs From Phantom Gains

A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.

Ограничение на превишените бизнес загуби по член 461(l): Ръководство за 2026 г. за собственици на дружества с прехвърляне на доходи

Член 461(l) ограничава превишените бизнес загуби за 2026 г. на $128 000 за неженени и $256 000 за съвместно деклариращи, съгласно OBBBA. Собствениците на дружества с прехвърляне на доходи използват Формуляр 461, за да декларират ограничението.

Section 163(j) Business Interest Limitation: The 30% ATI Cap and OBBBA's EBITDA Restoration

OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.