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Partnerships

Partnership accounting, profit sharing, and financial management

How Should States Tax Partnership Income? Inside the MTC's Blended Apportionment Proposal

The Multistate Tax Commission's January 2026 white paper proposes a "blended" apportionment method that folds a partnership's sales, property, and payroll factors into each partner's own state tax calculation. Because states currently split between aggregate and entity sourcing theories, the same partnership dollar can be taxed twice — or not at all. Here's what multistate partnerships and multi-member LLCs should track now.

When a Deficit Restoration Obligation Isn't One: What CCA 202628009 Means for Partnership Loss and Liability Allocations

IRS Chief Counsel Advice CCA 202628009 (July 10, 2026) held that a demand-based deficit restoration obligation enforceable only by withholding future distributions is not unconditional, failing both the §1.704-1(b) economic-effect safe harbor and the §1.752-2(b) recourse-liability test — a fact pattern common in family LP boilerplate that can reallocate recourse debt and suspend previously deducted losses.

Opportunity Zones 2.0: A 2026 Planning Guide for Real Estate Sponsors and Family Offices

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.