Welcome back! Ask questions, get answers, and join our large community of tax professionals.
cancel
Showing results for 
Search instead for 
Did you mean: 

UPE and basis adj

bcarrillo
Level 1

Current year UPE exceeds a partner's basis resulting in basis limited disallowed partner expenses. Is an adjustment to increase outside basis "Additional amounts invested in activity in current year" on the 1040 (K-1 basis input section) appropriate here? It seems such can be treated as a deemed capital contribution; however, guidance to support treatment is not clear.

0 Cheers
2 Comments 2
TaxGuyBill
Level 15

I'm not sure of the answer, but wouldn't it just be a suspended expense/loss, just like if the K-1 had a loss that was limited due to Basis? 

I understand your thought about a deemed capital contribution.  I haven't seen anything that allows an option/election to treat UPE as a capital contribution, but maybe I just haven't heard of it.

0 Cheers
bcarrillo
Level 1

Thanks for the feedback.

0 Cheers