Level 11
11-28-2023
02:23 PM
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These are partnerships that already have a 754 election in place, and the request is, "tell us what your outside basis is and we'll run it through"? In that case, there's nothing you need to do. Your client will probably get an AAR with their 2023 K-1.
Or this is a partnership that has no 754 election in place, but has expressed a willingness to elect for 2022, pursuant to Reg Sec 301.9100-2? Client should carefully read the operating agreement for language to the effect of "the person making such request shall pay all costs incurred by the Company in connection therewith, including reasonable attorneys’ and accountants’ fees."