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Entity StructureTax Tip #339: Special Allocation in Partnership Agreement
Real estate partnerships can allocate income, losses, and depreciation differently among partners through special allocations. For example, allocating 90% of depreciation losses to the high-income partner and 90% of cash flow to the partner who needs income. Special allocations must have "substantial economic effect" under IRC Section 704(b) and be documented in the partnership agreement.
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