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ARTICLE · 30 SEPTEMBER 2024

Drafting Partnership Agreements: Ensuring You Get The Returns You Bargained For

PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements.

United StatesTax

PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements.1 For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they should be used before entering into a partnership agreement.

In this Alert, we cover the following topics:

  • What are PIP allocations?
  • How do PIP allocations work?
  • Choices in applying PIP allocations
  • When they are useful?
  • When they are less useful?
  • When they are at odds with other allocations?
  • Whether PIP allocations obviate the need for special allocations like nonrecourse deductions, minimum gain, qualified income offset, and curative allocations

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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