Question
Owen Halsey and Prince Roberts are equal partners in an accrual-method, calendar-year partnership. Pursuant to the partnership agreement, Owen Halsey performs managerial services for the
Owen Halsey and Prince Roberts are equal partners in an accrual-method, calendar-year partnership. Pursuant to the partnership agreement, Owen Halsey performs managerial services for the partnership in his capacity as a partner. (a) Owen Halsey is entitled to a flat salary of $50,000 per year. The partnership pays Owen Halsey $50,000 for his services for 2019 in January of 2020. What are the tax consequences to the partners and the partnership if the partnership has $100,000 of capital gain income? What are the effects if the partnership has $25,000 of ordinary income (and must use $25,000 of its cash reserves to pay Owen Halsey)? (b) Owen Halsey's salary is equal to 20% of the partnership's taxable income. The partnership has $100,000 of taxable income ($60,000 of capital gain and $40,000 of ordinary income). What are the consequences to the partners and the partnership? (c) What are the tax consequences to the partners and the partnership if, instead of managerial services, Owen Halsey receives a flat salary of $50,000 for his performance of services related to capital improvements to the partnership's assets? (d) What are the tax consequences to the partners and the partnership if the partnership pays Prince Roberts "interest" at 8% per annum on his capital contribution?
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