Determine Partnership Basis And Capital Accounts
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CPA Regulation (REG) › Determine Partnership Basis And Capital Accounts
EF LLC (taxed as a partnership) has two equal partners, E and F. On January 1, E contributes $30,000 cash and F contributes services with an agreed value of $30,000 in exchange for a 50% capital and profits interest. Capital accounts are maintained under Treasury Regulations §1.704-1(b)(2)(iv), and the LLC has no liabilities. Which item affects F's capital account but not F's outside basis at formation under Internal Revenue Code §722?
The partnership's inside basis in contributed property under Internal Revenue Code §723
The $30,000 value of services credited to F's capital account
F's share of partnership liabilities under Internal Revenue Code §752
E's $30,000 cash contribution
Explanation
Internal Revenue Code §722 establishes a partner's basis from contributions, excluding services which are not 'property' under §721. F contributes services valued at $30,000, credited to capital but not increasing outside basis, as services trigger income recognition under §83 but basis remains zero per §722. The $30,000 affects capital but not basis, aligning with the distinction between book capital and tax basis. Choices B, C, and D are incorrect as they involve property basis or liabilities, which do not apply to services. Specifically, choice C relates to E's cash, not F's basis. Professionals must differentiate capital account credits from tax basis adjustments, especially for non-property contributions. A key rule is that basis from services is zero unless cash or property is also contributed, with value taxed as income.
What is Kim's adjusted basis in her partnership interest at the end of the year?
$70,000
$65,000
$75,000
$105,000
Explanation
A partner's basis is increased by their share of both taxable and tax-exempt income and decreased by distributions. Kim's share of ordinary income is \(50% * $80,000 = $40,000\). Her share of tax-exempt income is \(50% * $10,000 = $5,000\). Her ending basis is calculated as: Beginning basis ($60,000) + Share of ordinary income ($40,000) + Share of tax-exempt income ($5,000) - Cash distribution ($30,000) = \($75,000\).
Sara received a 25% interest in the capital and profits of the RST Partnership for services rendered. The fair market value of the partnership interest she received was $40,000. In addition, Sara's share of partnership liabilities at the time she was admitted was $15,000. How much income must Sara recognize, and what is her initial tax basis in the partnership interest?
$25,000 income; $25,000 basis
$40,000 income; $40,000 basis
$40,000 income; $55,000 basis
$55,000 income; $55,000 basis
Explanation
When a partnership interest is received for services, the fair market value of the interest is treated as compensation and is recognized as ordinary income by the partner. Therefore, Sara must recognize $40,000 of income. Her initial basis is the amount of income she recognizes ($40,000) plus her share of partnership liabilities ($15,000). Thus, her initial basis is \($40,000 + $15,000 = $55,000\).
What is Ann's adjusted basis in her partnership interest after accounting for the change in liabilities?
$70,000
$50,000
$60,000
$100,000
Explanation
An increase in a partner's share of partnership liabilities is treated as a cash contribution, which increases the partner's basis. The total increase in nonrecourse liabilities is \($150,000 - $90,000 = $60,000\). Ann's share of this increase is \(1/3 * $60,000 = $20,000\). Her adjusted basis is her basis before the change ($50,000) plus her share of the liability increase ($20,000), for a total of \($70,000\).
What is the maximum amount of the partnership loss that Marta can deduct on her personal tax return for the year, and what is her ending basis?
$45,000 loss; ($5,000) basis
$40,000 loss; $0 basis
$35,000 loss; $0 basis
$45,000 loss; $0 basis
Explanation
A partner's basis is first increased by income items and then decreased by losses. Marta's basis is first increased by her share of portfolio income: \($35,000 + (50% * $10,000) = $40,000\). Her share of the ordinary loss is \(50% * $90,000 = $45,000\). However, a partner can only deduct losses up to their basis. Therefore, Marta can deduct only $40,000 of the loss. Her basis is reduced to zero. The remaining $5,000 loss is suspended and can be carried forward indefinitely.
What is Paul's basis in the land after the distribution, and what is his remaining basis in the partnership interest?
$80,000 in land; $0 in partnership interest
$80,000 in land; ($10,000) in partnership interest
$70,000 in land; $0 in partnership interest
$100,000 in land; ($30,000) in partnership interest
Explanation
In a non-liquidating distribution of property, the partner's basis in the distributed property is the same as the partnership's basis (a carryover basis), but it cannot exceed the partner's basis in the partnership interest. Here, the partnership's basis in the land ($80,000) is greater than Paul's outside basis ($70,000). Therefore, Paul's basis in the land is limited to $70,000. His basis in the partnership interest is reduced by the basis he takes in the land, so \($70,000 - $70,000 = $0\).
What is Dale's adjusted basis at the end of the year?
$90,000
$50,000
$80,000
$60,000
Explanation
A partner's basis is adjusted for their share of income and changes in liabilities. The decrease in partnership liabilities is treated as a cash distribution. Dale's share of the liability decrease is \(25% * $40,000 = $10,000\). His share of the ordinary income is \(25% * $80,000 = $20,000\). His ending basis is: Beginning basis ($40,000) + Share of income ($20,000) - Deemed distribution from liability decrease ($10,000) = \($50,000\).
What is Ethan's initial tax basis and book capital account in his partnership interest?
Tax basis of $50,000; Book capital account of $50,000
Tax basis of $30,000; Book capital account of $50,000
Tax basis of $50,000; Book capital account of $30,000
Tax basis of $30,000; Book capital account of $30,000
Explanation
A partner's initial tax basis in a partnership interest received for a property contribution is the adjusted basis of the property contributed. Therefore, Ethan's tax basis is $30,000. A partner's book capital account under Section 704(b) is generally credited with the fair market value of the property contributed. Therefore, Ethan's book capital account is $50,000. This creates a book-tax difference.
Which of the following events will cause a partner's adjusted basis in their partnership interest to decrease?
The partnership makes a charitable contribution.
The partner guarantees a portion of the partnership's debt.
The partnership earns tax-exempt interest income.
The partnership sells a Section 1231 asset at a gain.
Explanation
A partner's basis is decreased by their distributive share of partnership losses and non-deductible expenses that are not capital expenditures. Charitable contributions are separately stated items that are non-deductible at the partnership level but flow through to the partners, decreasing their basis. Tax-exempt income and Section 1231 gains increase basis. Guaranteeing debt can increase a partner's share of recourse liabilities, which increases basis.
What is Yasmine's adjusted basis in her partnership interest?
$100,000
$300,000
$50,000
$200,000
Explanation
A limited partner generally does not have an economic risk of loss for recourse liabilities, so they are not allocated any basis from them (unless they guarantee the debt). Nonrecourse liabilities are allocated to all partners, typically based on their profit-sharing ratio. Yasmine's basis is her initial basis ($50,000) plus her share of nonrecourse liabilities \(50% * $100,000 = $50,000\). Her total basis is \($50,000 + $50,000 = $100,000\).