Tax Provisions In Partnership Agreements

Door Skinss | In Niet gecategoriseerd | on oktober 10, 2021

On December 12, 2017, Congress passed a law originally called the Tax Cuts and Jobs Act, which proposes a wide range of tax changes. The law was signed by the president on December 22. This disclaimer briefly summarizes some of the main income tax provisions of the Act with respect to partnerships and their partners. Planning Notice: In light of this new deduction, Pass-Through companies and their owners should consider reviewing the tax allocation rules of current shareholder and corporate agreements to determine whether changes to these provisions are warranted. Article 704 regulates only the allocation of tax items and not the allocation of economic items. Tax legislation cannot regulate how the partners agree to distribute the economic results of the partnership. This is why the partnership contract is the last word on the distribution of economic items between the partners. `applicable partnership participation` means an interest in partnership that the taxpayer receives in connection with the provision of essential services provided by the taxable person (or a related person) in the context of the negotiation or transaction of raising or returning capital and either of investment or disposal of securities, commodities, immovable property, means of payment or cash equivalents, options or derivatives held for rental or investment purposes; and similar interests or the development of such assets.

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