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Partnership doozy

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    Partnership doozy

    I have some questions and problems regarding a tiered LLC partnership structure. SE tax, significant or material participation vs. investor activities, bifurcation of profits vs. capital. Proposed 1402 reg carve outs that disallow bifurcation for certain industries. Consideration of an S Election vs. the BIG tax. That sort of stuff.

    Would anyone be willing to PM me and help me out by phone and/or email if you have experience with these issues? I'm well versed, well organized and have done my research. I figure about 2 -3 hours tops.

    Thanks.
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