A partnership pays no federal income tax. Instead, its income, deductions, and credits are allocated among its partners at the end of its taxable year. A partnership’s distribution of cash or property in kind to a partner will be characterized as one of three distinct transactions, each of which has its own tax consequences.
Douglas A. Kahn,
Proposed Regulatory Change of Treatment of a Guaranteed Payment from a Partnership to a Partner,
Mich. Bus. & Entrepreneurial L. Rev.
Available at: http://repository.law.umich.edu/mbelr/vol5/iss2/2