Skip to content
SimplyCPA
Glossary/Special allocations

What is Special allocations?

In short

A partnership agreement can allocate income, gain, loss or deductions among partners differently from their ownership shares. The allocation is respected only if it has substantial economic effect.

Key takeaways

  • Economic effect generally requires proper capital accounts, liquidating distributions based on them, and a deficit restoration obligation or qualified income offset.
  • Allocations without substantial economic effect are reallocated based on the partners' interests in the partnership.
  • Allocations of built-in gain on contributed property follow separate rules.

Where it's tested

REG: Partnership Taxation — study notes, a five-minute revision sheet and practice questions.

Practise: 3 questions

Question 1 of 3 · 0 answered

A partner has an outside basis of $20,000, which includes a $12,000 share of partnership liabilities. The partnership repays all of its debt. What is the tax consequence to the partner?

Browse all 886 terms