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A real estate limited partnership (RELP) is one of the most popular partnerships used for real estate transactions. In a RELP, tax implications can vary based on your role as the partner.
Example: A and B each contribute $10,000 in cash to form the AB Partnership. AB buys real property for $120,000, paying $20,000 and giving a recourse note for $100,000. The partnership agreement allocates all items equally to the partners. To determine each partner's economic risk of loss, a constructive liquidation analysis must be performed.
Partner A may decide to sell 25% of his equity to partner C. Partner B may decide to sell 50% of his equity to partner C. Partner C will own (15% + 20%) 35% of the partnership equity. Example 2. Assume now that there are three partners. Partner A owns 50% interest, Partner B owns 30% interest, and Partner C owns 20% interest.
Direct participation programs are most commonly formed to invest in real estate, energy, futures & options, and equipment leasing projects. A DPP is typically organized as a limited partnership or limited liability company, structures that enable the income and losses of the entity to flow-through to the underlying taxpayer on a pre-tax basis ...
Real estate can be a stable and lucrative asset class. Yet, the process of acquiring, managing and selling properties could also be overwhelming for individual investors. This is where real estate ...
For example, if Ann is a general partner of ABC partnership, Ann's tax basis in the partnership may be increased if the partnership borrows money. Special allocation rules for debt vary, depending on whether the debt is considered to be recourse or non-recourse to the partners in a partnership.
In 1981, Apache Corporation formed the United States' first MLP, Apache Petroleum Company (APC). Apache’s success drew other oil and gas companies to the MLP structure. Real estate companies soon followed, and by the mid-1980s, MLPs became so popular that they were adopted in a variety of industries, such as restaurants, hotels and cable TV.
FLPs are partnerships limited to family members, hence the name. FLPs are typically holding companies, acting as an entity that holds the property (business interests, real estate investments, publicly traded or privately held securities) contributed by the members.