14 Jan 2025
New Year Insights: Partnership Agreements and Allocations
The allocations that partners establish in their partnership agreement determine each partner's distributive share. A partner’s distributive share is that fraction of a partnership's items of income, gain, loss, deduction, and credit that the partnership agreement allocates to that partner in a particular taxable year. The partnership agreement is the starting point for the Internal Revenue Code's analysis of the partners' distributive shares. Totally separate from a partner's distributive share is the partnership's actual distributions to a partner.
Related Content
- Partnership Taxation: Partnership Distributions under Code Section 731
See how, under I.R.C. Section 731, distributions to partners are generally tax-free—an important tax characteristic of pass-through entities. But partnerships (and limited liability companies (LLCs)) distribute both cash and property in many different situations and for many different reasons. The result is that many exceptions apply to make certain types of distributions taxable.
- Advanced Taxation Issues for Partnerships and LLCs
Delve into the complexities of partnership taxation. A partnership's capital accounts reflect the financial relationships among the partners, which is the current status of the business and economic deal agreed to by the partners and incorporated into the partnership agreement.
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Review this resource kit linking to Practical Guidance content addressing the taxation of pass-through business entities such as partnerships, LLCs, S corporations, and their owners.
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
- Tax Key Legal Developments Tracker (Federal) (Current)—keep up to date with key legal developments!
- Business Entities. IRS provides transitional relief from penalties for certain brokers who fail to report sales of digital assets, as defined in Reg. §1.6045-1(a)(19), other than digital assets not required to be reported as digital assets pursuant toTreas. Reg. §1.6045-1(c)(8)(ii), (iii), or (iv), on information returns (Form 1099-DA, Digital Asset Proceeds From Broker Transactions), or fail to furnish payee statements under I.R.C. Section 6045. I.R.S. Notice 2025-3. See Information Reporting by Non-custodial Brokers of Digital Asset Transactions.
- Business Entities. IRS provides the optional 2025 standard mileage rates for taxpayers to use in computing the deductible costs of operating an automobile for business, charitable, medical, or moving expense purposes. The standard mileage rate for business-use transportation or travel expenses for 2025 is 70 cents per mile. I.R.S. Notice 2025-05.
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- Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts.
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Review this informative guide featuring some of the recent content additions to Practical Guidance, designed to help you find the tools and insights you need to work more efficiently and effectively. - The Practical Guidance Journal features guidance on the use of AI in employment decisions, AI considerations in acquisition agreements, Chevron deference reversal challenges in FDA rulemaking, 50 years of ERISA pension protection, plus obligations and risks related to the provision of anti-overdose medication in the workplace.
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