Draft instructions authorize use of ‘snapshot’ calculations.

For the 2020 tax year (returns filed in 2021) nearly all partnerships will be required to report the ‘tax capital’ of their partners and certain related information. As many are aware, this practice was phased-in for certain partnerships in the 2018 and 2019 tax years (returns filed in 2019 and 2020). Unfortunately, compliance with these new requirements was burdensome for many partnerships. This is mainly because it requires an analysis of historical tax and financial data that may not be readily available or may not even exist. 

Draft instructions for the 2020 tax year — just released on Oct. 22, 2020 — provide welcome relief in the form of simplified calculation methods. 

  • In lieu of an in depth analysis of actual historical data, partnerships would be authorized to utilize one of three simplified methods to calculate their partners’ opening tax capital balances for the 2020 tax year. These “snapshot” methods use current year data that nearly all partnerships should have readily at hand.
  • Once that “snapshot” opening tax capital balance is established for each current partner, the partnership may use a “transactional” approach to update and maintain those balances for future years. This is good news for many partnerships since the transactional approach is the method they already use to maintain and report the tax capital of their partners.

These methods generally follow the concepts and methods that the IRS described and sought public comment on earlier this year. See, Notice 2020-43, discussed in more detail here. The draft instructions include an additional optional method that allows a partnership to compute tax capital by utilizing section 704(c) balances.

In addition to the release of the draft instructions for 2020, the IRS noted that it intends to provide penalty relief for partnerships that may not be able to follow the new instructions perfectly, as long as they take “ordinary and prudent business care in following the form instructions to calculate and report the beginning capital account balances”. 

Although these new calculation methods will reduce the reporting burden for many, this process may still be complicated and time consuming in some cases. Partnerships that have not yet addressed these reporting requirements for 2020 are well advised to start the process as soon as practicable.

This article was written by Nick Passini and originally appeared on 2020-10-20.
2022 RSM US LLP. All rights reserved.

The information contained herein is general in nature and based on authorities that are subject to change. RSM US LLP guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. RSM US LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein. This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer.

RSM US Alliance provides its members with access to resources of RSM US LLP. RSM US Alliance member firms are separate and independent businesses and legal entities that are responsible for their own acts and omissions, and each are separate and independent from RSM US LLP. RSM US LLP is the U.S. member firm of RSM International, a global network of independent audit, tax, and consulting firms. Members of RSM US Alliance have access to RSM International resources through RSM US LLP but are not member firms of RSM International. Visit rsmus.com/aboutus for more information regarding RSM US LLP and RSM International. The RSM(tm) brandmark is used under license by RSM US LLP. RSM US Alliance products and services are proprietary to RSM US LLP.

Keegan Linscott & Associates, PC is a proud member of RSM US Alliance, a premier affiliation of independent accounting and consulting firms in the United States. RSM US Alliance provides our firm with access to resources of RSM US LLP, the leading provider of audit, tax and consulting services focused on the middle market. RSM US LLP is a licensed CPA firm and the U.S. member of RSM International, a global network of independent audit, tax and consulting firms with more than 43,000 people in over 120 countries.

Our membership in RSM US Alliance has elevated our capabilities in the marketplace, helping to differentiate our firm from the competition while allowing us to maintain our independence and entrepreneurial culture. We have access to a valuable peer network of like-sized firms as well as a broad range of tools, expertise, and technical resources.

For more information on how Keegan Linscott & Associates, PC can assist you, please call (520) 884-0176.