Читать книгу Taxation Essentials of LLCs and Partnerships - Larry Tunnell - Страница 6

For tax purposes, a partnership exists when two or more taxpayers join together, without incorporating, to carry on business or investment activities for their mutual (or “joint”) benefit. Partnerships can be used to conduct active businesses or to carry on investment activities. Moreover, the partnership can be structured in such a way that some partners participate actively in partnership operations while others play the role of passive investors, content to share in the profits (or losses) derived from partnership operations while playing no active role in day-to-day management activities. The primary strength of the partnership as a vehicle for conducting business is its flexibility. Partners can, for example, agree to share differently in the risks and rewards associated with partnership business activity. Yet, the partnership can still provide limited exposure to business risks for certain of its partners (for example, limited partners), providing the best of both worlds: (a) highly flexible arrangements for sharing in the risks and rewards of business activities and (b) limited liability for members. Moreover, unlike corporations, partnership income is subject only to one layer of tax-imposed at the partner level. For these reasons, partnerships are the preferred form of organization for a wide variety of business activities.