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Unlike the rules that apply to C corporations, which tax income both at the entity and at the owner level, the partnership rules are designed to only tax income once, at the owner level.

A partnership’s income, losses, deductions, and credit are passed through to the partners for Federal tax purposes and taxed directly to them, regardless of when income is distributed.[1] Since the partners have already paid tax on the income when it is earned, a complex system of rules applies to prevent double taxation when the income is later distributed to the partners.

No gain or loss is recognized to a partnership on a distribution of property or money to a partner.[27] The one exception is for disproportionate distributions, which are treated as a sale or exchange by the partnership.

Comparison to Corporations: Because no gain or loss is recognized on a distribution of money or property to a partner, partners are able to defer recognition of the gain in the appreciated property.

In contrast, distributions of appreciated property by C corporations and S corporations are treated as though the property were sold to the shareholder at fair market value.[28] For S corporations, this deemed sale results in gain recognized by the S corporation, which is passed through to the shareholders and increases their basis in the S corporation stock.[29] The distribution then reduces the shareholder’s basis.[30] Assuming the S corporation has no accumulated earnings and profits, the shareholder will have no gain on the later distribution except to the extent that the amount of the distribution exceeds his adjusted basis in the stock.[31] A partner may withdraw from a partnership by either sale or liquidation of his partnership interest.

A partner’s sale of his partnership interest is taxable.

This discussion of the tax consequences of contributions to partnerships will also apply to limited liability companies unless the limited liability company has elected to be taxed as a corporation.

A partner will not recognize gain or loss on a distribution, with three exceptions: If the partner receives an in kind distribution from the partnership (other than a liquidating distribution), the partner’s basis in the property received equals the property’s adjusted basis in the hands of the partnership immediately before the distribution (but not in excess of the partner’s basis in his partnership interest), less any money distributed in the same transaction.[25] A partner’s basis in property distributed in kind as part of a liquidating distribution is the same as his basis in the partnership, reduced by money distributed to him in the same transaction.[26] Important Note: Special rules apply to disproportionate distributions of partnership assets that include unrealized receivables (as defined in Code § 751(c)) and substantially appreciated inventory (as determined by Code § 751(b)(3)(A) and (d)).

These rules (a) allocate the partnership’s income, losses, deductions, and credit among the partners and (b) adjust basis to reflect each partner’s allocation of those items.

As stated in Taxation of Limited Liability Companies and Partnerships, limited liability companies are taxed as partnerships by default.

An election is provided by section 754 which ensures, by adjusting inside basis, that this equality is in fact always maintained so long as the election is made soon enough.

Indeed, the basis adjustments provided by the section 754 election are so well designed – and the equality been aggregate inside and aggregate outside basis so important – that commentators have called for making these basis adjustments mandatory rather than optional.[8] When an election under section 754 is made, the electing partnership becomes subject to two basis adjustment provisions: (1) section 734(b), providing for certain inside basis adjustments upon the occurrence of specified triggering distributions of cash or property from the partnership; and (2) section 743(b), providing for certain inside basis adjustments upon the sale or exchange of a partnership interest.




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