Partnership Taxation Flashcards
The form that must be filed when eligible business entties (i.e. all entities other than corps) choose how they will be classified for federal tax purposes
Form 8832; if not filed, an entity will be classified under default rules
A business entity with at least 2 members can choose to be classified as either of these
Corporation or partnership; default rule= partnership
A business entity witha single member may choose to be classified as eihter of these
Corporatration or disregarded as an entity separate from its owner; default rule= disregarded
Preferred form of business for real estate ventures requiring significant capital contributions
Limited partnership
Preferred entity of choice for service providers such as architects, accountants, attorneys, and physicians (b/c only liable for own negligenc,e malpractice, fraud)
Limited liability partnership
A partnership that has elected to be taxed under a simplified reporting system that does not require as much separate reporting to partners as does a regular p-ship
-must not be a service p-ship and must have 100 partners and file an election to be one
Electing large partnership
A partnership whose interests are traded on an established securities exchange or in a secondary market and are generally taxed as C corps
Publicly traded partnership
Generally the same as a partner’s regular partnership basis, but with the exception that this basis includes only liabilities for whcih the partner is personally liable
At-risk basis; deductibility of partnership losses is limited to this amount
Payments to apartner determined without regard to income of the partnership–deductible by the partnership and reported as income by the partners
Guaranteed payments
Contributed property to a partnership that is then distributed with 7 years to a partner other than the one who contributed it, the contributing patner must recognize this up to the difference in FMV and basis at time of initial distribution
Precontribution gain/loss
