Perhaps the most misunderstood aspect of partnership taxation relates to distributions. When a partnership distributes cash or property to its partners, the tax consequences can range from completely tax-free to significantly taxable, depending on how the distribution is structured and the partners' tax basis in their partnership interests. In this article, we'll explore the rules governing partnership distributions and how they impact partners' tax situations. More importantly, we'll look at strategies to structure distributions in the most tax-efficient manner possible – because the goal is not just to understand the rules but to use them advantageously.
Help Your Clients Implement a Fortune 500 CFO Strategy
Randy Sadler, CIC Services
For decades, some of America’s largest corporations have used a financial strategy that gives their CFOs greater control over insurance costs, helps them finance risks the commercial market handles poorly and creates an opportunity to retain underwriting profit when losses come in below expectations. Approximately 90% of Fortune 500 companies have captive insurance subsidiaries.¹ Historically, the economics favored organizations with substantial capital, large insurance programs and the resources to support their own insurance operations. Small and midsize businesses rarely had the scale to justify the cost and complexity. That equation has changed. A mature network of specialized insurance professionals and structures now allows qualifying privately held businesses to pursue many of the same risk-financing advantages. Federal tax law can further improve the economics for certain smaller insurance companies. For CPAs and tax professionals, this creates an advisory opportunity. The challenge is recognizing which clients could benefit and what conditions must exist before recommending it.
