#partnerships
Partnership accounting, profit sharing, and financial management
Georgia's HB 463 cuts the flat income tax rate from 5.19% to 4.99% for tax years starting January 1, 2026, with conditional annual cuts toward 3.99% — but the pass-through entity tax (PTET) rate stays at 5.75%, so S-corp and partnership owners who made the election should rerun the math against their SALT cap savings.
A 35-year-old is six times more likely to become disabled than to die before 65, yet most buy-sell agreements only plan for death. How disability buy-out (DBO) insurance funds a co-owner buyout — elimination periods, cross-purchase vs. entity redemption, and why premiums are nondeductible but proceeds are tax-free.
On April 6, 2026, the IRS opened its free Business Tax Account portal to partnerships, tax-exempt organizations, and government entities, letting a designated official view balances, download an EIN verification notice, and make payments online instead of mailing paper forms.
Roughly 54% of business partnerships dissolve within five years and about 70% of small business owners never signed a buy-sell agreement, leaving price, timeline, and process to be fought over from a blank page once partners can no longer agree.
For 2025 tax year returns filed in 2026, the IRS charges partnerships and S-corps $255 per partner or shareholder per month for late Forms 1065 and 1120-S, plus $330 per late Schedule K-1, while a new automatic relief program forgives first-time penalties for taxpayers with three years of clean compliance history.
Late Schedule K-1s are the norm, not the exception — a Form 7004 extension pushes partnership and S-corp returns, and every K-1 tied to them, to September 15, a full five months past the April 15 personal deadline. The fix is a simple playbook, file Form 4868, pay at least 90% of a good-faith estimate, and amend with Form 1040-X once the real numbers arrive.
OBBBA raises the federal SALT cap to $40,400 for 2026 with a 30-cent-per-dollar phase-out above $505,000 MAGI, then reverts to $10,000 in 2030. PTET elections in 36 states remain uncapped and still beat the cap for most high-income pass-through owners. State deadlines, bunching priorities, and the 2030 cliff explained.
The One Big Beautiful Bill Act made Qualified Opportunity Zones permanent and introduced rolling 5-year deferrals, decennial map redesignations starting July 1, 2026, a new rural fund class (QROF) with a 30% basis step-up at year 5, and $10,000-per-return reporting penalties. Here is the planning sequence for sponsors and family offices through the 2026–2027 window.
The One Big Beautiful Bill Act made Section 199A permanent, added a $400 minimum deduction for active small-business owners starting in 2026, and widened the joint phase-in range to $150,000. A field guide to the three QBI tiers, wage tuning, UBIA, aggregation, and SSTB positioning for pass-through owners.
Since the Tax Court's 2023 Soroban decision, a state-law limited partner label no longer shields distributive share from 15.3% self-employment tax. This guide walks through the functional test under Section 1402(a)(13), the Renkemeyer line of cases, the 2024 proposed regulations, and the planning moves that still hold up for fund managers, LLC members, and operating partners in 2026.
OBBBA made the Section 199A pass-through deduction permanent and widened the 2026 phase-in to $201,750 single / $403,500 MFJ. Here is how the 20% QBI deduction, the W-2 wages and UBIA caps, the SSTB phase-out, the new $400 minimum, and Form 8995-A aggregation actually work for S-corps, LLCs, and partnerships.
Section 736 splits liquidating payments to a retiring partner into 736(b) property payments (capital gain, no firm deduction) and 736(a) income or guaranteed payments (ordinary income with self-employment tax, deductible by the firm). The service-partnership carve-out, Section 751 hot assets, and Section 754 election together determine whether six- or seven-figure tax dollars land on the retiree or the firm.
