We appreciate the strong support and encouragement that we have received from Limited Partners
and we remain committed to focusing our efforts on continued operational improvements at the Partnership's inns.
Because LLC members can participate in the LLC without losing limited liability, the rule applicable to limited partners
who cannot participate in the management of the partnership without losing their limited liability should not apply.
The exceptions would apply if, immediately after the individual acquires that class of interest, (1) limited partners
own a substantial, continuing interest in that specific class of partnership interest and (2) their rights and obligations for that specific class of interest are identical to the rights and obligations of that specific class of partnership interest held by the limited partners
Rather than convert his general partner interest to a limited partner
interest, Dick decides he and Doug should simply exchange their partnership interests.
Recommendation: New businesses should explore this SE tax-saving opportunity, while existing LLCs should review their operating agreements to ensure that the limited partner
requirements are met.
New businesses should explore this SE tax-saving opportunity; existing LLCs should review their operating agreements to ensure that the limited partner
requirements are met.
The board unanimously recommended that the limited partners
reject the amended tender offers and not tender any of their limited partnership interests.
The general partner was a Corporation; the limited partners
The deferred contracts consisted primarily of partnership agreements with limited partners
entered into by the former Cardinal Industries, Inc.
There is a general belief that the posting of a recapture bond is cost-prohibitive to such a deal, but in fact, good refinancing will provide an inflow of capital, reduce interest payments and provide conditions for an easy exit of the limited partner
," continued James.
1402(a)(13), the distributive share of any item of income or loss of a limited partner
generally is not subject to SE tax.
The distributive share of a limited partner
is not subject to self-employment (SE) taxes.