PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. 1 For this reason, Investors and managers should understand the basics of PIP allocations and ...
A partnership is the fastest-growing form of operating a business in America. Partnerships offer much flexibility in tax reporting. The most significant element of this flexibility is the partners’ ...
The partnership agreement often provides for the allocation of separately stated items of partnership income, gain, loss, deductions and credits among the partners (known as a partner’s distributive ...
On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752[1] regarding the ...
The allocation of a partnership’s liabilities can have important tax consequences. A partner’s tax basis in his partnership interest includes his share of the partnership’s liabilities. A partner’s ...
Partnerships (which, for the purpose of this article, include limited liability companies treated as partnerships for tax purposes) have long been considered a flexible way of structuring investment ...