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Mateo Gonzalez

How to Properly Report Partnership Distributions When a Partnership is a Recipient

I'm struggling with a unique partnership tax situation and could use some advice from anyone who's dealt with this before. I'm preparing taxes for a client who has a partnership (let's call it Partnership A), and another partnership (Partnership B) owns 90% of Partnership A. Partnership B recently received a distribution from Partnership A of around $340,000, but Partnership B only has a basis of about $290,000 in Partnership A. This results in a taxable gain of roughly $50,000. Partnership B has two individual partners - one owns 51% and the other owns 49%. I'm confused about where to report this gain on Partnership B's return. Should I report this capital gain on Form 1065's Schedule D for Partnership B? Or should I report the full distribution on Schedule K of Form 1065 and have the individual partners report their respective portions of the gain on their personal income tax returns? I've reviewed the instructions but still feel unsure about the proper treatment when one partnership receives distributions from another partnership where it's a partner. Any guidance would be greatly appreciated!

Nia Williams

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This is a common area of confusion. When Partnership B receives a distribution exceeding its basis in Partnership A, you're correct that the excess creates a taxable gain. For tax reporting purposes, you should report the capital gain on Partnership B's Form 1065 Schedule D. This gain flows through to the partners via Schedule K-1, Box 9a (net long-term capital gain). The individual partners will then report their proportionate share (51% and 49%) on their personal returns. The full distribution itself is not reported on Schedule K - only the taxable portion (the gain amount). The distribution that represents return of basis is not taxable and simply reduces the partner's basis. Make sure you're tracking Partnership B's basis in Partnership A correctly. The $50,000 gain exists because the distribution exceeded the outside basis, and this needs to be properly documented in your workpapers.

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Luca Ricci

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Thanks for the explanation. Quick follow-up question: does it matter if the distribution was cash or property? And what if the partnership had Section 751 "hot assets" - would that change how it's reported?

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Nia Williams

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The form of distribution does matter. If the distribution was in cash, it's handled exactly as I described above - reported on Schedule D when it exceeds basis. If the distribution was property, you generally don't recognize gain unless it's marketable securities or "hot assets." For Section 751 "hot assets" (unrealized receivables or substantially appreciated inventory), special rules apply. The distribution would be divided between the Section 751 assets and other property. The gain attributable to Section 751 assets would be reported as ordinary income rather than capital gain, typically on Form 4797 rather than Schedule D. The remaining gain would still go on Schedule D.

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Yuki Watanabe

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I'm skeptical about AI tax tools. How accurate was it really? Partnership taxation has so many nuances...did it actually catch things you might have missed or just give generic advice?

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Yuki Watanabe

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Andre Dupont

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Zoe Papadakis

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They use a system that continually redials and navigates the IRS phone tree until they reach a human. It's not about cutting the line - they're just automating the frustrating part where you're sitting on hold for hours. When they get a live person, they connect that call to your phone. I had the same reaction as you initially - thought it might be incorrect info. But I actually got connected with someone in the business tax department who knew partnership rules well. She walked me through the exact sections of the 1065 instructions that applied to my situation and explained how to document the distribution properly. The advice was consistent with what my tax research showed, but it was reassuring to have official confirmation.

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Zoe Papadakis

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I need to eat my words about Claimyr. After our discussion, I was still skeptical but desperate because I had a similar partnership distribution issue with a looming deadline. Gave it a try and, surprisingly, they got me through to someone at the IRS within 40 minutes. The agent I spoke with was incredibly knowledgeable about partnership distributions and confirmed that for a partnership receiving distributions from another partnership, the gain should indeed be reported on Schedule D of Form 1065 when it exceeds basis. He even emailed me the specific sections of the regulations that applied. I'm actually shocked this worked. I've literally spent days trying to get through to the IRS on my own with no success. If you're facing partnership tax questions that need official clarification, it's definitely worth trying.

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ThunderBolt7

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Don't forget about Section 734 adjustments if the partnership has a Section 754 election in place! This can affect basis and how the distribution is taxed. I'd check if either partnership has a 754 election before finalizing how to report this.

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I completely forgot about the 754 election possibility! I need to check if either partnership has that in place. How would that change the reporting if Partnership A has a 754 election in effect? Would that affect how Partnership B reports the distribution?

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ThunderBolt7

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If Partnership A has a 754 election in place, it doesn't change how Partnership B reports the distribution - Partnership B would still report the gain on its Schedule D when the distribution exceeds its basis. The 754 election affects Partnership A internally. With this election, Partnership A would adjust the basis of its assets to account for the difference between Partnership B's inside and outside basis. This helps prevent double taxation or tax shifting among partners, but it doesn't change Partnership B's obligation to report the gain on the excess distribution.

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Jamal Edwards

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Just a heads up - I made a mistake on this exact issue last year. I reported the entire distribution on Schedule K instead of just the gain on Schedule D, and it caused a mess with the partners' personal returns. One partner got audited because the numbers didn't reconcile. The safest approach is definitely Schedule D for the gain portion only, like others have mentioned. Don't make my mistake!

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Mei Chen

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How did you resolve the audit? Did you have to file amended returns for the partnership and all partners?

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Jamal Edwards

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Yes, we had to file an amended 1065 for the partnership, correctly reporting the gain on Schedule D instead of Schedule K. Then each partner had to file amended personal returns to reflect the corrected K-1 information. The worst part was explaining to the partners why they needed to amend. The IRS was actually pretty reasonable once we corrected everything, but it was a stressful few months and cost my client additional fees for all the amended filings. The lesson I learned was to be very careful with partnership distributions and always trace through how they affect both the partnership and individual returns.

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Chloe Harris

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This is a great discussion with solid advice. Just to add one more consideration - make sure you're properly tracking the basis adjustments for Partnership B going forward. After recognizing the $50,000 gain from the excess distribution, Partnership B's basis in Partnership A should be reduced to zero (since the distribution exceeded basis). This zero basis will be important for future distributions, allocations of income/loss, and any potential sale of the partnership interest. I'd recommend documenting this basis adjustment clearly in your workpapers and keeping detailed records, especially since partnership basis tracking can get complex over multiple years. Also, double-check that Partnership A properly reported this distribution on their Schedule K-1 to Partnership B. The amounts should reconcile between what Partnership A shows as distributed and what Partnership B received.

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This is excellent advice about the basis tracking! I'm new to partnership taxation and didn't realize how critical it is to maintain detailed records of basis adjustments over time. One question - when Partnership B's basis gets reduced to zero after this distribution, how does that affect their ability to deduct their share of Partnership A's future losses? I assume they can't deduct losses below zero basis, but I want to make sure I understand the mechanics correctly for future years. Also, should I be maintaining a separate basis schedule for Partnership B's investment in Partnership A, or is there a standard worksheet format that most practitioners use for this type of tracking?

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