Question
Tammy, Rebecca, and Miriam are partners in TRM Consulting, LLC, which will receive partnership tax treatment as the default for tax purposes. Tammy, Rebecca, and
Tammy, Rebecca, and Miriam are partners in TRM Consulting, LLC, which will receive partnership tax treatment as the default for tax purposes. Tammy, Rebecca, and Miriam contribution $50,000, $25,000, and $25,000 of cash. In addition, the partnership agreed to take on a non-recourse loan of $20,000 from Miriam. Rebecca would like to contribute services to the partnership and is considering asking for additional profits interest in return for the service. Without the service, Tammy, Rebecca, and Miriam’s profits interests would be 50%, 25%, and 25%, respectively. Answer the following questions to help Rebecca think about what would happen if she performs the services for the additional profits interest.
Fill in the blank: Continuing from part a., how much would Rebecca’s service in exchange for profits interest change each partner’s outside tax basis (if at all)? If there is change, make sure it is clear whether the change is positive (increases outside tax basis) or negative (decreases outside tax basis). Rebecca's outside tax basis would change by $_______.
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