Tag Archive: "Partnership Agreements"
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Deficit Restoration Obligations in Partnership Agreements
In last week’s blog post, we shared two concepts that are essential to understanding partnership allocations under Internal Revenue Code (IRC) Section 704. While last week’s blog post focused on the role of Substantial Economic Effect in partnership agreements, today’s blog post will stress the importance of Deficit Restoration Obligations (DROs) in partnership agreements. DROs […]
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Understanding Substantial Economic Effect in Partnership Agreements
Partnerships provide a valuable framework for collaboration in business, but navigating the tax implications of partnership agreements can be complex. One critical, yet often overlooked concept, is the determination of a partner’s distributive share of allocable partnership items, which is covered under Internal Revenue Code (IRC) Section 704. Under IRC Section 704(b), if a partnership […]