Partnership Tax Liability Allocation Problem 1

preview_player
Показать описание
Partnership Tax Liability Allocation Problem 1.
Рекомендации по теме
Комментарии
Автор

Hello my friend, quick question on this -

For prong 2 of NR debt allocations, say for example a partner contributes land with basis of $0, NR debt of $100. Assume the FMV is greater than debt, and the pship has no other liabilities.

It is clear the $100 NR debt is 704(c) debt under prong 2. What is not clear is what is the contributing partners outside basis? Is it $0 or $100?

As I understand, generally, you would decrease the outside basis by the total liability contributed, then increase for the partners share. Would this result in $0-$100+$100 = $0 outside basis, or am I missing something?

Thanks!

ericwdcuhw
Автор

Awesome video, thank you! Quick question: this concept applies to when the partnership purchases an asset subject to a liability after the partners already contributed cash correct?

Phrased another way: if a partner instead contributed land with a liability attached, the liability would be allocated based on the profit ratios, and the contributing partners basis would decrease based in liabilities allocated to existing partners. The existing partners basis would increase from their share of the new debt?

ericwdcuhw
Автор

Question for 2) if Apple defaults on the loan, can Pear sue Apple for recovery on the loss. This would ultimately leave Apple, the one guaranteeing the loan, with the entire economic risk and therefore full allocation of the liability.

Honestcritic
Автор

Is the result different if a limited partner contributes property with a recourse liability which the limited partnership assumes? If say, for example, the FMV exceeds the Adjusted Basis of the property, but the recourse liability amount is greater than the adjusted basis in the property?

danakeller
join shbcf.ru