The Callaway Real Estate Limited Partnership was formed on January 1, 2015. Their business consists of purchasing, constructing, and managing residential real estate. Currently, Callaway is under the accrual method of accounting and has a calendar year end. Under the partnership agreement, Callaway has one general partner, Tambour Properties Inc., who provides all staff and services. In return, Tambour receives an annual management fee of 5% of gross rental income earned by the partnership. The other 95% of partnership taxable income is allocated to the limited partners based on their percentages specified in the partnership agreement. The partnership agreement also specifies that partners' capital accounts are determined and maintained by Section 704(b) regulations, and that as general partner Tambour must restore any deficit balance in their capital account upon liquidation …show more content…
(2) Is the management fee paid to the general partner, Tambour, treated as a guaranteed payment or part of their distributive share? (3) What amount of loss is allocable to the limited partner, Dr. Ashin, in this taxable year? (4) Of the allocable amount, how much is deductible and are there any limits on how much she can deduct this year? (1) The payment is equal to 5% of gross rental income earned by the partnership, which is earned regardless of the overall net income of the partnership for the year. (2) Since the management fee is based on gross rentals regardless of the net income of the partnership, it should be treated as a guaranteed payment to Tambour under IRC §707(c). (3) Of the net taxable loss for the year of the partnership, $292,324 is allocable to Samantha. (4) Based on the allocable amount, Dr. Ashin is limited by her adjusted basis of $125,000 under IRC §704(d), and is limited to a deduction of $13,200 based on passive activity limitations under IRC
60. During the year 2014, Ricki, who is not self-employed and does not receive employer reimbursement for business expenses, drove her car 5,000 miles to visit clients, 10,000 miles to get to her office, and 500 miles to attend business-related seminars. All of this mileage was incurred ratably throughout the year. She spent $300 for airfare to another business seminar and $200 for parking at her office. Using the automobile expense rates in effect for 2014, what is her deductible transportation
When Lambert resisted the idea of a full base salary structure, AAA suggested 5% of the salary bonus be based on commission. Lambert countered offered with 10% -- which was dismissed. Past experience indicates property performance tied to salary compensation is successful, so Lambert proposed 5% of the salary bonus be based on commission with the pay structure be revisited after one year to slowly change the salary structure toward the bulk of salary be commissioned, this was agreed on by both parties. The second biggest issue was team management and cross-training. Lambert proposed the local management team be vetted by AAA with training provided by Lambert – this would require annual mandatory training of AAA upper management team to be in attendance. This proposal was meet with irritation by AAA, offended that their management training was considered less than ideal. Additionally, AAA informed Lambert that local law requires AAA to provide training. Lambert elaborated on the management training with expectation of training to be given by AAA to their own middle management team, allowing for free movement of training. AAA would manage their local training with Lambert assistance when needed.
Adefmi explained that additional rent is based on 9.54 % of the operating expenses of the property-owner.
After a review of the concerns presented in Ms. Edwards’ inquiry to your office, we have determined that Keelin Edwards has met her $500.00 calendar year deductible.
Property Complex is a calendar year, cash-basis taxpayer. It entered into a contract with Management Company which manages large commercial property complexes. In addition to paying for a fixed $5,000 per month, Property Complex would pay extra 1% of gross rents received in excess of $1,000,000. Management Company and Property Complex are not related entities. Property Complex prepaid management fees one month in advance. On October 1, 2015, Property Complex prepaid $35,000 which is the total amount of management fees and 1% contingent fees in five months to Management Company because of
It is a liability if Anne needs to settle the payout, however after she consulted with the lawyer, she should be able to get a refund of $800,000. The expense should be corrected in 2018 once the payout is returned to Anne, and it should be recorded as receivables for the amount to be paid.
Certain provisions outside of Subchapter K affect the amount of loss that an individual partner can deduct in any given year. Two major provisions are the at risk limitations and passive loss rules which are next. At risk limitations Although a partner may have sufficient basis to claim a loss, at risk limitations may restrict a partner from deducting losses where there is no financial risk of loss. IRC Sec. 465(a) A partner's at-risk amount generally includes his adjusted basis in the partnership taking into account only those liabilities for which the partner has personal liability. This is in contrast to a partner's outside basis computation which may include the partner's share of all partnership liabilities without regard to any personal liability on the obligations, Thus, a partners outside basis may include both recourse and nonrecourse liabilities,
In note 21 of the financial report, this section deals with interest bearing liabilities, current finance leases liability is 0.4 million
Net Loss – The combination of the operating loss and the non-operating gain produced a net loss of $162k compared to a budgeted loss of $143k. YTD operating and non-operating losses are $384k compared to a budgeted gain of $988k.
Estimated net income (loss) in 1984 excluding accounting and other charges identified in part A
You can set your own rental rate or let RelayRides set a suitable rate. You keep 75 percent of all earnings, which are deposited
Upon review this cession, it is unclear how this loss triggers/falls within our 1999 contract period of 09/01/99 – 08/31/00. Could you kindly review with Zurich American Insurance Company (Zurich) and provide clarification how our contract responds to this.
She has heard that such losses are given special treatment under the Act. Briefly explain to Justina the special treatment given to business investment losses in the year of loss and in future years. Assume that Justina will earn $75,000 in salary in 2012 and has never claimed the lifetime capital gains deduction. Detailed calculations are not necessary.
As a result, the wife would have a total exemption amount of $8.86 million, which is inclusive of her $5.43 million exemption plus the deceased husband’s $3.43 million deceased spousal unused exclusion amounti
The amount of £300,000 is used to create a discounted discretionary trust using an investment bond, Jeans is the (Settlor) and both her children are made the trustees and her wishes have been made known to them. As a standard process of establishing the trust a discount has to be determined and this is done