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Yuki Tanaka

Understanding Guaranteed Payments to Partners Discrepancy on 1065 vs Schedule M-1

I'm reviewing a partnership tax return and noticed something weird about guaranteed payments to partners. On their Form 1065, they show an expense for guaranteed payments. Then on Schedule K, they add back the exact same amount. I get that part - it's just for reporting so the income shows up on individual K-1s. But here's where I'm confused... on Schedule M-1, they're reporting a guaranteed payment to partners expense that's LESS than what's on both the 1065 and Schedule K. How is this possible? Why would there be a difference between these amounts? Shouldn't they all match up? I've been staring at this for hours and can't figure out what I'm missing. Any tax pros here who can explain this discrepancy?

The difference you're seeing is likely due to timing differences between book and tax reporting. On Form 1065 and Schedule K, the partnership reports the total guaranteed payments for tax purposes. On Schedule M-1, the partnership reconciles book income to tax income. If the amount on M-1 is smaller, it could mean that some guaranteed payments were accrued for book purposes in the previous year but paid (and therefore deductible for tax purposes) in the current year. Or perhaps some guaranteed payments were capitalized for book purposes (like if they related to acquiring or developing an asset) but fully deducted for tax purposes. Look at the previous year's return to see if there's a corresponding difference there. Also check if there are any footnotes or explanations attached to Schedule M-1 that might clarify the reconciliation items.

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Thanks for the explanation. I get what you're saying about the timing differences, but could there also be a situation where guaranteed payments include both cash and non-cash benefits? Like health insurance for partners or something similar? Would those be treated differently on M-1 vs the 1065?

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You're absolutely right that guaranteed payments can include non-cash benefits like health insurance premiums paid for partners. For tax purposes, all guaranteed payments (cash and non-cash) would be included on Form 1065 and Schedule K. Some non-cash items might be treated differently for book purposes, which could explain the discrepancy on M-1. For example, the partnership might expense health insurance premiums for partners immediately for tax purposes but amortize them for book purposes. Or the partnership might be on a different accounting method for certain non-cash benefits.

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To the original question - check if the partnership is maintaining separate book and tax capital accounts. If so, the difference you're seeing might be related to Sec. 743(b) adjustments if there was a partnership interest transfer with a 754 election in place. Those adjustments can create exactly the kind of discrepancy you're describing between the various forms.

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Can you explain what a 743(b) adjustment is in simple terms? I'm still learning partnership taxation and I keep seeing this mentioned but don't fully understand how it impacts guaranteed payments.

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A Section 743(b) adjustment happens when someone buys an interest in a partnership for more (or less) than their proportionate share of the partnership's basis in its assets. When a partnership makes a 754 election, it adjusts the basis of its assets to account for this difference, but ONLY with respect to the new partner. This adjustment doesn't directly impact guaranteed payments themselves. However, it can create differences between book and tax reporting that show up when reconciling on Schedule M-1. For example, if assets with 743(b) adjustments are used in activities that generate guaranteed payments, the depreciation or amortization related to those adjustments might create book/tax differences.

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Ava Kim

Surprised nobody mentioned checking if any of the guaranteed payments were for services related to capital expenditures? If partners performed services for capital projects, those guaranteed payments might be capitalized for book purposes but still fully deducted as guaranteed payments for tax purposes in the current year.

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This is exactly what happened with a partnership I worked with! They had partners doing architectural design work on a new building, paid them guaranteed payments, but for book purposes those were capitalized into the building cost while for tax they were deducted immediately. Created the exact discrepancy OP described.

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Great discussion everyone! I've seen this exact discrepancy many times in my practice. The most common causes are: 1. **Timing differences** - Guaranteed payments accrued in one period but paid in another 2. **Capitalization issues** - Some guaranteed payments capitalized for book purposes (like partner services for asset development) but fully deducted for tax 3. **Non-cash benefits** - Health insurance, retirement contributions, etc. that may have different book vs. tax treatment To troubleshoot, I always recommend: - Compare the current year M-1 with prior year to spot patterns - Review the partnership agreement for any unusual guaranteed payment structures - Check if any partners provided services related to capital projects or asset acquisitions - Look for footnotes or workpapers that explain the M-1 reconciling items The key is that Schedule M-1 reconciles book income to taxable income, so any item treated differently between financial reporting and tax reporting will create these discrepancies. It's actually quite normal and doesn't necessarily indicate an error - just different accounting methods being applied.

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This is such a helpful summary! I'm dealing with a similar situation right now where guaranteed payments for partner consulting services on equipment purchases are being capitalized for book purposes but deducted for tax. Your point about checking the partnership agreement is spot on - ours has some unusual language about how partner services are compensated that I think is creating the complexity. Quick question: when you mention reviewing prior year M-1, are you looking for the reverse adjustment (where book income was higher than tax income) in the previous period?

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@Anna Xian Exactly right! When guaranteed payments are capitalized for book purposes in the current year but deducted for tax purposes, you should see the reverse pattern in future years. As the capitalized asset gets depreciated or amortized for book purposes, book income will be lower than tax income assuming (no corresponding tax deduction .)This creates a predictable pattern on M-1 over multiple years - the initial year shows book income higher than tax income due to the capitalization, then subsequent years show book income lower than tax income as the book depreciation/amortization is taken. Also worth checking: if the partnership is using different depreciation methods for book vs. tax like (straight-line for book, accelerated for tax ,)that can compound the timing differences and make the M-1 reconciliation more complex. The partnership agreement language you mentioned might specify how to handle these situations, especially if partners are providing both capital and services.

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I've been following this thread and wanted to share another scenario that can cause these discrepancies - **partner benefit plans**. If the partnership pays for things like disability insurance, life insurance premiums, or contributes to SEP-IRAs for partners, these are treated as guaranteed payments for tax purposes but might be handled differently on the books. For example, some partnerships will record life insurance premiums as a direct expense for book purposes (reducing book income) but report them as guaranteed payments for tax purposes (which get added back on Schedule K). This creates exactly the kind of M-1 difference you're seeing. Also check if the partnership made any **Section 199A deduction adjustments** related to guaranteed payments. While guaranteed payments don't qualify for the 199A deduction, if the partnership incorrectly included them in QBI calculations and then had to make corrections, this could show up as reconciling items on M-1. Have you looked at the specific line items on Schedule M-1 to see which reconciling adjustments are creating the difference? That might give you a clearer picture of what's causing the discrepancy.

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This is really helpful! I hadn't considered the partner benefit plans angle. Looking back at the return I'm reviewing, I can see there are some insurance premiums that might be causing part of the discrepancy. One quick follow-up question - when you mention Section 199A adjustments, are you referring to situations where guaranteed payments were initially misclassified as distributive share items that would qualify for QBI, and then corrected? I'm still getting familiar with how 199A interacts with partnership taxation and want to make sure I understand the mechanics correctly. Also, you're absolutely right about checking the specific M-1 line items. I was so focused on the total guaranteed payments number that I didn't dive into the individual reconciling adjustments. Going to pull that detail now - thank you for pointing me in the right direction!

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