Capital Accounts: 704(b) vs. GAAP vs. Tax Basis, Comparing ...
Jun 01, 2021 · 2. Liquidating distributions made in accordance with positive Section 704(b) Capital Accounts; and 3. In lieu of a DRO, the partnership agreement contains a Qualified Income Offset (“QIO”) provision. Economic Effect Equivalence. Partnership agreement does not satisfy the General or Alternate Test of economic effect.
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