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Partnerships

Partnership accounting, profit sharing, and financial management

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16 min read

Section 163(j) Interest Expense Limitation: 30% ATI, the Small Business Exemption, and the Real Property Trade Election

Section 163(j) caps the business interest deduction at 30% of adjusted taxable income, and OBBBA restored the EBITDA-style add-back for tax years beginning after December 31, 2024. This guide walks through the calculation, the small business exemption under Section 448(c), the irrevocable real property trade or business election, the partnership EBIE basis trap, and the Form 8990 reporting choreography.

Mike Thrift

taxtax-planningtax-deductions
14 min read

Form 8308 and Section 751 Hot Assets: Why Selling Your Partnership Interest Often Costs More Than You Think

Selling a partnership interest can convert expected capital gain into ordinary income under Section 751, raising the federal tax bill on the recharacterized slice from 23.8 percent to 37 percent. This guide explains Form 8308, hot-asset categories, the January 31 partner statement deadline, and what sellers, buyers, and partnership administrators need to do for 2025 and 2026 transfers.

Mike Thrift

partnershipstaxcapital-gains
15 min read

Form 8825 Demystified: How Partnerships and S-Corps Report Rental Real Estate Without Triggering an IRS Letter

Form 8825 consolidates partnership and S-corp rental real estate activity, with line 21 flowing to Schedule K-1 box 2 where each owner applies the passive activity loss rules under Section 469. The December 2025 revision splits gross rents from other rental income and adds Schedule A's twenty named expense categories for Schedule M-3 filers. Owners hit basis, at-risk, and passive walls in that order before a loss reaches Form 1040.

Mike Thrift

real-estatepartnershipss-corp
11 min read

Form 8865 Foreign Partnership Reporting: The Four Categories of Filers, the $10,000 Penalty, and How U.S. Persons Stay Off the IRS Radar

Form 8865 is the U.S. information return for foreign partnership interests, with $10,000 per-partnership per-year penalties for non-filing. This guide breaks down the four filer categories under Sections 6038, 6038B, and 6046A, the constructive ownership rules that catch most surprise penalties, and the schedules each category must include.

Mike Thrift

taxinternational-taxpartnerships
13 min read

Schedules K-2 and K-3 in 2026: The Domestic Filing Exception, the 1-Month Deadline, and the Foreign Tax Credit Trap

Schedules K-2 and K-3 pulled even purely domestic partnerships and S-corps into international tax reporting starting in 2021. This guide explains the 2026 filing rules, the four-condition domestic filing exception, the January 15 partner notification and February 15 1-month K-3 request deadlines for calendar-year filers, the $250,000 small entity carve-out added in 2024, and the per-partner, per-month penalty math for non-compliance.

Mike Thrift

taxtax-compliancepartnerships
12 min read

Section 199A QBI Aggregation Election Under Reg 1.199A-4: How Pass-Through Owners Combine Commonly Controlled Trades or Businesses to Beat the W-2 Wage and UBIA Limits

The Section 199A aggregation election under Reg 1.199A-4 lets pass-through owners combine commonly controlled trades or businesses before applying the W-2 wage and UBIA of qualified property limitation. This guide walks through the five eligibility tests, the Form 8995-A Schedule B disclosure, the irrevocable consistency rule, and when pooling QBI across an operating-and-leasing or multi-entity structure actually unlocks more deduction.

Mike Thrift

tax-planningtax-deductionss-corp
11 min read

Family Limited Partnership Valuation Discounts in 2026: How Wealthy Families Quietly Shave 25–40% Off Estate and Gift Tax Bills

A practical 2026 guide to Family Limited Partnership valuation discounts — how high-net-worth families combine 10–25% lack-of-control and 20–35% lack-of-marketability discounts to cut estate and gift tax exposure, with worked numerical examples, the IRC Section 2036 traps that have collapsed estates in Tax Court, setup costs, and the bookkeeping required to defend the structure on audit.

Mike Thrift

estate-planningtax-planningpartnerships
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