Partnership elections grid.

BY THE AICPA TAX DIVISION'S PARTNERSHIP TAXATION TECHNICAL RESOURCE PANEL (TRP)

The AICPA Tax Division's Partnership Taxation TRP developed a Partnership Elections Grid to benefit AICPA Tax Section members; a portion of the Grid is reproduced below. It is a quick reference tool for many of the elections and choices that tax advisers make for clients that operate as a partnership for Federal tax purposes, but does not purport to be all-inclusive.

Before filing returns, tax advisers should refer to the complete Grid (1) for additional elections and related items. Use of the Grid does not replace the need to review the authorities governing each item. For comments or more information, email mhyman@aicpa.org.

Manner of making Election election First-year elections 1. Election to Attach a statement to the deduct and partnership return. amortize partnership organizational expenses. 2. Election Attach a statement to a blank to be excluded Form 1065, U.S. Return of from the partnership Partnership Income. In certain rules. circumstances, if no election is filed, the partnership may he deemed to have made the election. 3. Election Attach a statement to the to apply the first partnership return filed proposed contingent after Sept. 22, 2003 and liability amend any open tax years to regulations. reflect the proposed regulations. 4. Election Attach a statement to the to deduct and partnership return. amortize start-up costs. 5. Election File Form 8716, Election To under Sec. Have a Tax Year Other Than 444 to use a Required Tax Year. other than a required tax year. 6. Ratable Attach a statement to the accrual of return. real property taxes. 7. Election By deducting the item on the to adopt the return in the first tax year recurring such expense is incurred. item method for certain expenses. Subchapter K elections 8. Optional Attach a statement signed by basis an authorized partner to the adjustment. partnership return. 9. Election Guidance has not yet been to exclude issued; it may be advisable to investment attach a statement to the partnerships partnership return. from mandatory basis adjustments. 10. Inside Attach a statement to the basis adjustment lower-tier partnership's to lower-tier return. Both the lower--and partnership the upper-tier partnerships assets on the must have a Sec. 754 election sale of in effect. an upper-tier partnership interest. 11. Inside Attach a statement to the basis adjustment lower-tier partnership's to lower-tier return. Both the lower--and partnership the upper-tier partnerships assets on must have a Sec. 754 election a distribution in effect. from the upper-tier partnership. 12. Adjustment Attach a statement to the to the basis of distribute partner's return. distributed property. 13. Basis Attach a statement to the proration on partner's return. liquidation of a partnership interest. 14. Designation File a statement with the of tax matters Internal Revenue Service partner (TMP). Center with which the partnership return was filed. 15. Termination Attach a statement to the of Sec. 444 return for the short period election to use...