@GlenBirnbaum “The revenue proposals are estimated relative to a baseline that incorporates all revenue provisions of Title XIII of H.R. 5376 (as passed by the House of Representatives on November 19, 2021), except Sec. 137601”.
All on top of BBB - Assumes BBB passed.
@JWellsCFO Yes - but sometimes the payee is a state for a withholding. Or it was a reclassified personal expense. Regardless, it should be closed out and not left with hanging balance at year end - which I believe is your point.
@ForemanTaxLaw@taxgirl@EmDeeEm@fintaxdude Then you get no SE as an S AND you can issue profits interests (which are always capital gains) as an LLC. It’s really the best of both worlds!
@SmithMatthewC Yes, but it would seem to me I have a decent argument - as with other credits - that my refund came first from estimates and withholding? I would really only have a potential pick up of schedule E income if I start to get a refund of that credit?
@taxchic_k Really only seems necessary if you would have otherwise had an E&P dividend or if not in income at all - a distribution in excess of basis.
@ForemanTaxLaw@AccountingAsArt If you are referring to what I think you are - NY setting a 10/15 due date for that election is just plain cruel though.
@cbriancpa@ForemanTaxLaw Yeah, but on the other hand - my experience is the that problem just the opposite in Texas - ‘it is a partnership, my single member LLC is the GP and I’m the LP!’
@davidsgamage@RichardRubinDC TBH - just got myself down a rabbit hole here after a long day and should have called it myself a while ago. Intent was just to note some weird results that may not be anticipated. I’ll bet good money that examples will be abundant next week. If not, I will.
@davidsgamage@RichardRubinDC As for the other partner, bigger problem is old losses. Assuming losses were fully taken against recourse debt, debt shift in current year under proposed rules may spring a gain. 2/2
@davidsgamage@RichardRubinDC At least under our current regime, once capital is depleted losses follow debt allocations. (Sometimes debt follows losses, but that method appears to disappear here). Didn’t see any suggestion that would change. 1/