Charitable donations

Corporate partners

Deeply discounted security, company partners' share

Exchange gains and losses, treatment of


Income tax profits, allocation of

Lone relationships

Allocating credits and debits to company partners

Company partners and other connections

Lending between partners and partnership

Mixed member partnerships

Anti-avoidance, individuals who are not partners


Counteraction: reallocation of profits

Excess loss allocation

Excess profit allocation rules, application of

Practical solutions

Preventing double taxation

Notional profit/loss, reallocation of

Profit sharing arrangements, changes

Salaries and interest on capital, treatment of