Minimum interest of a General Partner

Technical topics regarding tax preparation.
#1
Posts:
118
Joined:
8-Nov-2017 3:10pm
Location:
KY
Hi all..

An attorney for a client is forming a LP structure for one of his real estate development projects. The attorney suggests to form a LP with one general partner (LLC) with zero ownership interest. The State laws allow for a GP to own no ownership interests, but what about from the taxation point of view. How does the IRS take it..

I believe I had read somewhere in the past that the IRS has a safe harbor for general partners to own at least 1% in the ownership and economic interests otherwise the IRS would treat the LP as an association taxable as a corporation.. Cant find the code for reference.

Any one of you can shed some light on it..

Thank you
 

Return to Taxation



Who is online

Users browsing this forum: Anderly, CornerstoneCPA, Gjkycpa, Google [Bot], Google Adsense [Bot], GRobCPA, IDunnoItDepends, jhanle1948, JR1, jwmatorres, lckent, MichelleSCPA, SALYstrikesagain, SumwunLost, Taxes OHoulihan, Terry Oraha, TheAnswerMan, UnlicensedTaxPro, WaylonDenmark, zl28 and 154 guests