The formulas
- Basis before distributions = beginning + taxable income + tax-exempt income
- Distributions reduce basis; cash above basis is gain
- Then nondeductible expenditures reduce basis
- Loss allowed = min(loss, remaining basis); the rest is suspended
How it works
Section 705 starts with basis from contribution or purchase, adds the partner share of taxable and tax-exempt income, and subtracts distributions, the share of losses and nondeductible expenditures, not below zero. Section 704(d) allows a loss only up to the adjusted basis at the end of the partnership year, and the excess is allowed in a later year.
Cash distributed above basis immediately before the distribution is gain under section 731(a)(1). For the loss limit, Treas. Reg. 1.704-1(d)(2) first increases basis under section 705(a)(1) and decreases it under section 705(a)(2) for everything except losses, so the tool applies increases, then distributions, then nondeductible expenditures, and tests the loss last. The gain test treats the cash as distributed at year end, which fits draws and advances against the distributive share (Treas. Reg. 1.731-1(a)(1)(ii)); a mid-year distribution is measured against basis at that date. Partnership liabilities are not modeled, so include any liability share in your beginning basis if it applies.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Are partnership liabilities in basis?
This tool does not compute them. Include your liability share in the starting amount if it applies to you.
What happens to the suspended loss?
It is allowed at the end of a later partnership year in which basis is restored.
Are other loss limits applied?
No. This tool applies only the basis rules in sections 705, 704(d) and 731.
Sources
- 26 U.S.C. 705, Determination of basis of partner interest, Legal Information Institute
- 26 U.S.C. 704, Partner distributive share, Legal Information Institute
- 26 U.S.C. 731, Extent of recognition of gain or loss on distribution, Legal Information Institute
- 26 CFR 1.704-1, Partner distributive share, Legal Information Institute
Runs in your browser. The figures you type are not sent to CORAA or stored. Check the result against your firm's methodology before relying on it.