gxpopppl.ppt - Partnership Operations Partnership Level Tax...

Partnership Operations:
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Partnership Level
Tax Determinations
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Partner Tax Consequences
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Loss Limitations
© Copyright 1998, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009 James Edward Maule
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Partnership Level Tax Determinations
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Partnership as deemed taxpayer
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computed as though individual §703(a)(1)
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certain deductions (eg §§151, 170, 212, 213)
disallowed §703(a)(2)
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Holding period phenomenon
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Elections §703(b)
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Partnership taxable year
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Partnership method of accounting

Partner Tax Consequences
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concept of “flow through”
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taxed to partners, not partnership §701
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even if not distributed
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Note: P’shp can be liable as employer for
employment based taxes, withholding, etc.
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preservation of character and other attributes
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partner-level determinations (limitations, etc)
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need for separate statement §702(a)
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reported on various return schedules
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special rules for certain “large” partnerships
§ § 771-777
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