TCP — Quick Sheet
Partnership Compliance & Planning
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- Special allocations valid only with substantial economic effect
- §704(c): pre-contribution built-in gain/loss stays with the contributing partner
- Cash distributions tax-free to basis; liquidating loss only if solely cash/receivables/inventory
- §754 election aligns inside basis with the buyer's outside basis (§743(b) transfers, §734(b) distributions); binding going forward
- Loss limits in order: basis → at-risk → passive → excess business loss
- Guaranteed payments = ordinary + SE income to the partner