Читать книгу Taxation Essentials of LLCs and Partnerships - Larry Tunnell - Страница 36

A partner's share of partnership income or loss usually affects his or her rights to partnership assets. For example, if a partner contributes $12,000 to a partnership, and is allocated a $10,000 share of partnership income in the first year, he or she has a claim to $22,000 of the partnership's assets. If the partner receives no distributions in the current year, he or she expects to receive at least $22,000 in the future. Likewise, if the partner's share of partnership income or loss had been a ($2,000) loss, he or she would have a remaining claim against partnership assets of only $10,000 (the original $12,000 contribution, less the ($2,000) share of the partnership's operating loss). Note that the partner's claim against the partnership's assets is not the same as the partner's basis in his or her partnership interest. One reason these amounts differ is that the latter includes the amount the partner might have to pay should the partnership fail (that is, the partner's share of partnership liabilities).

The partner's share of the partnership's basis in partnership assets is called the inside basis. The partner's basis in the partnership interest, which includes the share of partnership liabilities, is referred to as the outside basis.

The partners' contributions to the partnership, and their rights to partnership assets, are reflected in the capital section of the partnership's balance sheets. For tax purposes the partnership maintains two sets of books and records. The first set reflects the partnership's tax basis in its assets and is used to determine the tax consequences of its transactions. The second set of records reflects the book value of the partnership's assets and is used to determine the economic consequences of partnership transactions.¹²