Sale of LLC inerest

Technical topics regarding tax preparation.
#1
BIGE48  
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One member of an three members LLC Co filing as an Partnership for taxes has decided to sell his interest to another member for $500,0000 .
The LLC has been in the commercial cleaning business for 13 years . Profits have been distributed annually to the three members .
The selling member has a $50,000 capital basis .

Are their any tax consequences other than the to the selling member recognizing a $450,000 capital gain on his personal 1040 income tax form ?
 

#2
Nilodop  
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Probably. What % did the seller own? Were there any liabilities? Was the partnership cash or accrual method? Were there any unrealized receivables? Was the consideration all cash? Were there loans from or to the selling partner? Was what you call the capital basis the member's tax basis? Was section 1060 considered? Is a 754 election in effect?
 

#3
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BIGE48 wrote:Are their any tax consequences other than the to the selling member recognizing a $450,000 capital gain on his personal 1040 income tax form ?


The gain may not be entirely capital in nature if there are any hot assets involved.
 

#4
jon  
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If "hot assets exist" there is a form I think 8303 which I think is attached to the seller's K-1 and gives the information necessary to record the ordinary income portion to the gain. Depreciation recap the toughest, and if the tax return is filed on the cash basis, any adjustments to accrual basis like like inventories, accounts receivable net of accruals ie net of payables would be ordinary income.
 


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