2026 Year-End Planning Summary
The retiring partner's buyout is a one-time window to make a §754 election worth an estimated $9,000–$14,000/year in incremental depreciation to the remaining partners, plus a guaranteed-payment classification review worth ~$4,000–$7,000 of SE tax exposure.
Each move as a range, stepping down from the current-path liability.
§754 election to step up inside basis on the retiring partner's buyout
Guaranteed-payment classification review for the two working partners
Addressed by the plan
2 of 2 quantified
Time-sensitive moves before December 31.
Multi-year planning to revisit beyond this season.
Items to resolve before the client conversation.
The partnership has relied on capital-account balances as a proxy for partner basis, but the two are not the same computation — capital accounts do not include a partner's share of partnership liabilities, which basis under §704(d) does. Before the §754 step-up is computed, the underlying inside-basis figures need to be confirmed independent of the capital accounts, and each remaining partner's own basis and at-risk position should be reconstructed so the buyout's downstream effects on loss deductibility are understood.
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