The return on investments after applicable income taxes are subtracted.
For example, an investment with a before-tax return of 8% would have an after-tax return of 5.8% for an individual in the 28% bracket.
Allocations of gain attributable to a decrease in partnership minimum gain (a “minimum gain chargeback,” as required under paragraph (f) of this section) cannot have economic effect because the gain merely offsets nonrecourse deductions previously claimed by the partnership.
Thus, to avoid impairing the economic effect of other allocations, allocations pursuant to a minimum gain chargeback must be made to the partners that either were allocated nonrecourse deductions or received distributions of proceeds attributable to a nonrecourse borrowing.
13, 66, and 91 and a rescission of FASB Statement No. 79-11Accounting for Nonrefundable Fees and Costs Associated with Originating or Acquiring Loans and Initial Direct Costs of Leases—an amendment of FASB Statements No.
13, 60, and 65 and a rescission of FASB Statement No. 10Designation of AICPA Guide and Statement of Position (SOP) 81-1 on Contractor Accounting and SOP 81-2 concerning Hospital-Related Organizations as Preferable for Purposes of Applying APB Opinion 20—an amendment of FASB Statement No.
To the extent a nonrecourse liability exceeds the adjusted tax basis of the partnership property it encumbers, a disposition of that property will generate gain that at least equals that excess (“partnership minimum gain”).
At retirement, accumulation units are converted to Annuity Units.
To calculate the current value of the accumulation, multiply the number of units owned by the current value of one accumulation unit.
Allocations of losses, deductions, or section 705(a)(2)(B) expenditures attributable to partnership nonrecourse liabilities (“nonrecourse deductions”) cannot have economic effect because the creditor alone bears any economic burden that corresponds to those allocations.
Thus, nonrecourse deductions must be allocated in accordance with the partners' interests in the partnership.