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https://www.irs.gov/businesses/small-businesses-self-employed/limited-liability-company-llcA Limited Liability Company (LLC) is a business structure allowed by state statute. ... Owners of an LLC are called members.
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Depending on elections made by the LLC and the number of members, the IRS will treat an LLC as either a corporation, partnership, or [a sole proprietorship].
https://www.washingtonpost.com/archive/realestate/1986/12/06/try-a-pig-or-a-pal/c9364c54-3251-4477-9e07-331a3dfe8af6/... Beginning Jan. 1, Americans who have sunk dollars into limited partnerships, rental condominiums, duplexes and other forms of real estate investment will find new restrictions on their ability to write off losses.
They will be stuck with a surfeit of unanticipated PALs, and be in dire need of some really fat PIGs.
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The most controversial section of the 1986 tax legislation classified virtually all real estate investments [other than first and second homes] as "passive," no matter how active they may be in reality.
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PALs, the economic and paper losses produced by so-called passive real estate, no longer can be used to offset income generated by salaries, dividends, bank accounts and other "nonpassive" income sources.
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Many real estate-partnership investors, however, own no rental homes. But, fortunately for them, an entire new subsector of American real estate investment is rising from the ashes of tax revision.
Good old-fashioned Yankee ingenuity is creating a bumper crop of PIG partnerships -- real estate investments designed to make money passively. ... So-called master limited partnerships (MLPs) are currently in [this] category.
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Appearances to the contrary notwithstanding, MLPs are bona fide limited partnerships. More than 25 MLPs, worth upwards of $ 4 billion, have either come to market since the summer or have been registered with the Securities and Exchange Commission. Most are real estate related.
“Asia and the Metals “ was a morning staple on F/A. Already running when I came there sometime around 2000. But @rono may have posted it on an earlier board before F/A. Asia was a different animal geopolitically 25 years ago. Folks who then complained that Asian workers were taking away U.S. jobs now complain that the cheap items they bought at KMart / Walmart in those days cost a lot more today.I've lost tract of when that was @hank. Definitely Fund Alarm days. I think I started watching FA around 2006-7 or so so probably around that time. PMs and Asia EM were the hot sectors. Harry Brown's permanent portfolio was also talked about a lot. (rono might have called the consistent post 'asia and the metals' now that I think about it).
https://taxfoundation.org/1980s-tax-reform-cost-recovery-and-the-real-estate-industry-lessons-for-today/Lessons for Today
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Long asset lives (for example, 27.5 years for residential buildings and 39 years for nonresidential buildings) in which deductions are spread over many decades mean that companies cannot deduct anywhere near the full value of their investments in structures, as inflation and the time value of money chip away at the value of those deductions. Shortening depreciation schedules to 15 or even 20 years, roughly where they were before TRA86, would lessen the magnitude of this problem, but it would not be the ideal policy.
The current system of depreciation creates a bias against businesses that heavily invest in structures, as the effective marginal tax rates on investments in nonresidential and residential structures are much higher than those on equipment, software, and intellectual property.
Journal of Accountancy, What Happened to Limited Partnerships?ONCE TOUTED AS THE INVESTMENT vehicle of the future, limited partnerships are seldom pitched to investors today. Instead, clients and the CPAs who advise them are looking back at the tax and financial factors that contributed to the downfall of LPs in areas such as oil and gas, real estate and equipment leasing.
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THE TAX REFORM ACT OF 1986, combined with increased Internal Revenue Service audit scrutiny spelled the beginning of the end for tax-oriented LPs. Extension of the at-risk limitations to real estate tax shelters and the passive loss provisions in the TRA [reducing the ability of individual taxpayers to offset income with losses from tax shelters] gave the IRS the weapons it needed.
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