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Partnership Taxation Issues in Estate Planning

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Top 7 Issues with Partnerships in an Estate or Trust. IRD of a ... in the same manner as if the decedent had directly held his pro rata share of each item. ... – PowerPoint PPT presentation

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Title: Partnership Taxation Issues in Estate Planning


1
Partnership Taxation Issuesin Estate Planning
By Carol A. Cantrell Houston, Texas
2
Top 7 Issues with Partnerships in an Estate or
Trust
  • IRD of a Deceased Partner
  • Section 754 Elections
  • Jobs Act Mandatory Negative Basis Adjustments
  • Distributions of Marketable Securities
  • Determining Trust Income from a Partnership
  • Allocating Taxes on Partnership K-1 Income
  • Partnership K-1 Capital Gains and DNI

3
IRD for S Corporations
  • 1367(b)(4) IRD of a deceased S corporation
    shareholder applies with respect to any item of
    income in the same manner as if the decedent had
    directly held his pro rata share of each item.
    (added in 1996).

4
Income in Respect of a Deceased Partner
  • 691(e) For application of this section to IRD
    of a deceased partner, see 753.
  • 753 The amount includible in gross income of
    a successor in interest of a deceased partner
    under 736(a) is IRD under 691.

5
736(a) Payments are IRD
  • 736(a) - all payments from an ongoing
    partnership in liquidation of a deceased or
    retired partners interest except 736(b)
    payments.
  • 736(b) payments for a partners interest in
    partnership property except a general partners
    share of cash basis accounts receivable and
    unstated goodwill in a service partnership.

6
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7
Dads Inside and Outside Basis
8
Mandatory Negative Basis Adjustment under
734(b)
9
Distribution ofMarketable Securities
10
Gain on Distribution ofMarketable Securities
11
With a 754 Election
12
With a 754 Election
13
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