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Foreign Source Income from Humanitarian and Developmental Aid Organizations
For purposes of K-2, K-3, is aid project income earned from international development organizations such as UNICEF, International Development Banks, etc, considered "Foreign Source"? These sort of funds typically have offices all over the world, including the USA. -
Installment Sale of Partnership Assets
Can you sell assets belonging to a partnership using an installment sale method similar to an individual selling property? Can the IRS Form 6252 be used the same way on a partnership as it would be used on an individual return? If so, how it reported on the IRS Form 1065 and to the K-1s? -
Liquidation of S-Corp and Partnerships
In a complete liquidation of a S-Corp, what are the reporting requirements (final balance sheet) and how do you figure the calculation of distribution to shareholders? Same question for Partnerships. Thank you! -
Using loans to offset negative capital accounts for Partnership to S-Corp conversion
A three-member LLC that has been taxed as a partnership has negative equity apportioned across all three capital accounts. The members want to elect S-Corp taxation, which as you all know is a deemed liquidation whose proceeds are used to buy shares in a new S-Corp and distribute those shares to the members, so the S-Corp inherits all liabilities... -
Foreign Partner without ITIN
Hello,
Can the partnership return be filed before the ITIN is secured by the foreign partner? One of the domestic partners claims that an IRS rep at the local office stated that they can write "applied for" for the ITIN. {I have contacted the IRS and spoke to several departments, but have not received a concrete answer, as... -
Partnership Return - Special Allocation of Depreciation
Okay, the operating agreement for a partnership-taxed LLC allocates all depreciation associated with property financed by a recourse loan to the member who cosigned for the loan. I can see from IRS Audit Guide for partnerships that this arrangement is perfectly reasonable (it's cited in Example 6-1 of the 2007 edition), but I want to be sure that... -
Can a partner opt out of a partnership's 401(k) plan?
Multi-member LLC taxed as a partnership had two members at the start of 2014 and agreed to establish a solo 401(k) plan to which the company would make a maximum non-elective contribution (20% of net income from self-employment). They added a new member in September, and the new member says he would prefer to forego his 401(k) contribution to keep... -
Basis limits on Publicly traded Partnership K-1
Good morning and please excuse my long post - I have been a lurker for years, and hope that I am including all info up front to support my questions. So here's the situation - A client has a PTP with a negative ending capital account under the "tax basis" on Part L of schedule K-1, from 2011 - the first year the ending basis was below zero.... -
Self-Rental of Home Office for MMLLC
A husband-wife multi-member LLC taxed as a partnership has an operating agreement that requires each member to maintain a home office. Presently, the members claim the expense of these home offices as UPE on their joint return (1040). The husband (who owns their current home solely in his name) wondered about the value of renting a portion of their... -
Amortization no longer taken
Hi,
I am working a Partnership return that I have taken over from a previous preparer. The P/S began in 2008 and the $6,618 start up costs were amortized to the limit of $5,000.
In 2009, an additional $108 was taken.
In 2010, a new preparer took over the return and did not amortize any of the remaining start up costs in either...