Capital Accounts Flashcards
What are the three types of capital accounts?
GAAP Basis, Tax Basis, 704(b) Basis
Sec. 704(b) capital account generally should reflect a partner’s?
Equity in the partnership
Sec. 704(b) capital account is increased to reflect?
- Amount of cash and/or net fair market value (FMV) of property contributed to the partnership;
- Partner’s allocable share of partnership income/gain.
The capital account is decreased to reflect:
- Amount of cash and/or net FMV of property distributed;
- Partner’s allocable share of partnership loss/deduction.
A partner’s Sec. 704(b) capital account generally cannot go negative unless..?
(unless there’s a DRO or the negative amount is required to be restored under
a minimum-gain chargeback provision)
Partnership may revalue assets and restate partners’ Sec. 704(b) capital accounts to reflect each partner’s
economic share of underlying assets at what value when certain events occur?
FMV
What are the events that permit a partnership to revalue assets and restate partners’ Sec. 704(b) capital accounts?
- Contributions of money/property by new or existing partner
- Distributions of money/property to a partner as consideration for a partnership interest
- Grant of partnership interests in exchange for services
- Issuance of non-compensatory options
A general principle of subchapter K is that tax allocations follow..?
Sec. 704(b) allocations
How is Sec 704(b) income calculated?
1.) Begin with taxable income
2.) Add back tax amount for Sec. 704(c) items
– Inventory
– Depreciation and amortization
– Gain/loss on sale of assets
– Contingent liabilities (i.e., non-tax liabilities)
3.) Add/subtract Sec. 704(b) amount for Sec. 704(c) items
– Depreciation and amortization
– Gain/loss on sale of assets
– Revaluation gain
4.) Add/subtract tax-exempt income and non-deductibles
What is the difference between a partner’s outside tax basis and a partner’s tax capital account?
Come Back
A partner’s ability to take partnership losses on an individual income tax return is limited if..?
Outside tax basis is zero.
Can a partner’s outside basis go negative?
No
What happens if a partner receives a distribution of cash or property that exceeds the partner’s outside basis?
The excess is taxable income to the partner
Gain or loss recognized on a sale of a partnership interest is calculated by reference to..? What happens if If the cash/other consideration exceeds the partner’s outside basis?
- Partner’s outside basis
- Partner recognizes gain on sale of the interest that’s reported on his/her individual income tax return