2020 K-1 question.- partners with negative tax capital account and final at the end of year. Do you keep ending negative capital? How do you track it next year (2021) on M-2 since that won’t be there.

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I think the partnership agreement dictates what happens in the event a partner has negative tax capital in order to maintain substantial economic effect.

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most likely just transfer the negative capital to the new partner or the remaining partners if it’s a redemption. is there any reason not to make a 754 election and step it up? not sure if the amounts are material.

Let’s say partnership agreement and everything is in tact and this was the result. No mandatory 754 election in place unless inside/outside tax basis is more than 250k

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Reallocated to the remaining partners. This results in a book - tax difference, and the necessity to keep partner basis schedules.

You can’t reallocate tax capital without income being reallocated.

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