partnership-allocation-engine

Section 704(b) tax allocations for real estate joint ventures are modeled by inputting GP/LP capital percentages, total capital, waterfall terms, property details, and hold period to generate annual allocations and capital account reconciliations.

A minimum gain chargeback impacts partnership capital accounts by requiring specific tax allocations to nonrecourse deduction beneficiaries. The engine models these chargebacks across hold periods to maintain capital account alignment and flag allocation risks.

UBIT and UDFI for pension LPs in a CRE partnership are calculated through optional REIT compliance testing. This analyzes tax allocations and exit waterfalls for real estate ventures including pension limited partners.

Tax versus cash distributions at exit are reconciled by applying the economic waterfall terms against accumulated capital accounts. The engine outputs a clear exit waterfall and tax vs. cash reconciliation for real estate joint ventures.

704(c) allocations for contributed property with built-in gain are handled by applying 704(c) considerations alongside 704(b) rules. This ensures tax allocations align with the underlying economic arrangement across formation and operation.