top of page


Partnership Tax Issues in LLC Operating Agreements: 704(c), Allocations, 754, and the Audit Rules
LLC operating agreements allocate tax items. Here is how Section 704(c), target allocations, Section 754 elections, and partnership audit rules should show up in the document.
Trenton Roberts
Jun 2410 min read


Profits Interests and Admitting New LLC Members
Profits interests are the tool many LLCs use when they want to admit a new member for services without handing over a slice of current capital. Done correctly, the grant can be respected as a partnership interest in future appreciation only, and the IRS safe harbors in Rev.
Trenton Roberts
May 2810 min read
bottom of page