Partnerships Flashcards

1
Q

WHAT is a partnership’s basis for determining depreciation on a building?

A

THE contributing partner’s basis at the time of contribution

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2
Q

HOW would you treat an increase in a partnerships’ liabilities?

A

By increasing each partner’s basis in proportion to their ownership

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3
Q

WHAT is considered a general rule when property is contributed to a partnership in exchange for a partnership interest?

A

NO gain or loss is recognized by the partner or the partnership

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4
Q

WHAT would be considered an individual partner election (rather than a Partnership election)?

A

Whether to take a deduction or credit for taxes paid to foreign countries

versus a Partnership-level election of accounting methods and/ or tax year to use

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5
Q

True or False.

A partnership generally terminates for tax purposes on the death of a partner.

A

FALSE.

A partnership generally does NOT terminate for tax purposes on the death of a partner

This is partly due to the fact that the deceased partner’s estate or successor in interest continues to share in partnership profits and losses

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6
Q

True or False.

A partner’s basis is increased by his or her share of partnership income and decreased by distributions.

A

TRUE.

A partner’s basis is increased by his share of partnership income and decreased by distributions.

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7
Q

HOW is a decrease in a partner’s share of partnership liabilities treated for tax purposes?

A

AS a distribution of money to the partner.

i.e. this reduces the partner’s share of basis by that same amount

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8
Q

WHAT is considered the “original basis” in a partnership interest of a person who acquired it by inheritance?

A

THE Fair Market Value (FMV) of the interest on the date of death

caveat. This is also based on whether or not estate does not elect the alternate valuation date

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9
Q

WHAT is NOT a consideration in determining the basis of a partner’s interest in a partnership for purposes of computing gain or loss on the sale or liquidation?

A

The partnership book value of the partner’s interest

i.e. The partnership book value of a partner’s interest has no effect on basis

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10
Q

WHERE would “Guaranteed payments” that were made by a partnership to partners for services rendered to the partnership (that are deductible business expenses) be reported?

A

ON the Schedule K-1 to be taxed as ordinary income to the partners

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11
Q

WHAT are the rules for a gain to be “capital” in nature in a partnership transaction?

A

(1) Item must have been held for more than 5 years; and

(2) have been a capital asset in the hands of the distributee partner

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12
Q

True or False.

Gain is not recognized by a partner on a distribution except to the extent that money distributed exceeds the partner’s adjusted basis in the partnership interest.

A

TRUE.

Note: The basis of property received in a distribution may NOT exceed the partner’s basis in the partnership interest less any money received in the distribution

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13
Q

WHAT would be considered “Hot assets” of a partnership?

A

(1) Unrealized receivables
(2) Inventory
i. e. Any gain realized attributable to “hot assets” is ordinary income. “Hot assets” include unrealized receivables and inventory

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14
Q

True or False.

A limited partnership is a pass-through (nontaxable) entity.

A

TRUE

A limited partnership is a pass-through (nontaxable) entity.

Note: Partners must report their shares of the limited partnership’s taxable and deductible items on their personal returns

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15
Q

HOW would you treat a transaction conducted by a partner with the partnership in a capacity other than that of a partner?

A

AS if it were with a third party after arm’s-length negotiation

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16
Q

WHAT is the procedure when a liquidation occurs and the partner’s basis in the partnership exceeds the partnership’s basis in the distributed assets?

A

THE excess between the two must be allocated among the distributed assets

17
Q

True or False.

A guaranteed payment is a payment to a partner that is determined by partnership income.

A

FALSE.

A guaranteed payment is a payment to a partner that is determined without regard to the partnership income

Note: These payments can be in addition to regular profit shares and are deductible by the partnership

18
Q

HOW are Nonrecourse and Recourse liabilities different when it comes to partnership losses?

A

Nonrecourse liabilities are shared based on partnership profit interests.

Recourse liabilities, on the other hand, are shared based on economic losses.

19
Q

WHAT is a condition for eligibility to make a Sec. 444 election (i.e. partnership electing to use a tax year different from their required tax year) under IRC?

A

THE partnership must choose a tax year in which the deferral period is not longer than 3 months.

i.e., the number of months between the beginning of the tax year selected and the end of the required tax year