#partnerships
Partnership accounting, profit sharing, and financial management
A 2026 LIHTC field guide for developers — how the 9% and 4% credits differ, how qualified basis and the 70%/30% present-value subsidies are calculated, the three overlapping compliance clocks, the IRS forms (8609, 8609-A, 8586, 8611), syndication mechanics, and the One Big Beautiful Bill Act changes that cut the bond financing test from 50% to 25%.
Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.
Starting filing season 2026, the IRS will apply First-Time Penalty Abatement automatically for taxpayers with a clean three-year compliance record — wiping Failure-to-File, Failure-to-Pay, and Failure-to-Deposit penalties without a phone call or Form 843. Here is how the rollout works, who qualifies, and when reasonable cause is the smarter move.
Form 8832 lets eligible entities — domestic LLCs and most foreign companies — elect to be taxed as a disregarded entity, partnership, or C corporation. This guide covers default classifications, the 60-month lockout, late-election relief under Rev. Proc. 2009-41, and how Form 8832 differs from Form 2553.
Section 162(l) lets self-employed taxpayers deduct 100% of medical, dental, vision, Medicare, and long-term care premiums above the line via Form 7206.
Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.
A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.
Section 461(l) caps 2026 excess business losses at $128,000 single and $256,000 joint, per the OBBBA. Pass-through owners use Form 461 to report the limitation.
Profits interests let LLCs grant equity to service providers tax-free under IRS Rev Proc 93-27.
A 2026 guide to the Pass-Through Entity Tax — how 36+ jurisdictions let S-corps and partnerships convert capped state income taxes into a fully deductible federal business expense, even after OBBBA raised the SALT cap to $40,400.
Schedule M-1 and M-3 reconcile GAAP book income to taxable income on Form 1120. Learn the $10M and $50M asset thresholds, permanent vs.
OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.
