70 tagged with "Partnerships"
Partnership accounting, profit sharing, and financial management
OBBBA SALT Cap and PTET: A Four-Year Window for Pass-Through Owners
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.
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.
Section 199A QBI Deduction in 2026: A Pass-Through Owner's Playbook After the One Big Beautiful Bill Act
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.
Section 1402(a)(13) After Soroban: The Limited Partner SE Tax Exemption in 2026
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.
The Section 199A QBI Deduction in 2026: A Permanent 20% Tax Break for Pass-Through Business Owners
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 Payments to Retiring or Deceased Partners: 736(a) vs. 736(b), Hot Assets, and the Goodwill Lever
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.
OBBBA Locks In the Section 199A QBI Deduction: A 2026 Playbook for Pass-Through Owners
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: Reconciling Book Income to Tax on Forms 1120, 1120-S, and 1065
Schedule M-1 reconciles book net income to taxable income on Forms 1120, 1120-S, and 1065. Walk through every line, the permanent versus temporary differences that drive the gap (federal tax, 50% meals, MACRS depreciation, deferred revenue), when Schedule M-3 takes over at $10 million in assets, and the workpaper discipline that keeps books and returns tied together.
Section 267 Explained: Related-Party Loss Disallowance and the Matching Rule
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.
Section 514 UDFI Demystified: How Nonprofits, Foundations, and Self-Directed IRAs Get Taxed on Borrowed-Money Investments
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.
MLP K-1 Tax Issues for Individual Investors: UBTI, Section 751 Recapture, and Multi-State Filings
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%.
MLP K-1 Tax Issues: UBTI, Section 751, and Multi-State Filings for Individual Investors
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.