Special Allocation Partnership Solution Set               Special Allocation Partnerships provide powerful business structures for pooling capital and creating liquidity. Partnerships can entail highly intricate structures subject to complex tax rules. By harnessing this complexity, the Advantage for Analysts® ("Advantage") Special Allocation Partnership Solution Set maximizes business performance by balancing investor interests, minimizes the time spent on bad deals, and avoids unpleasant compliance surprises. Solution Capabilities The Advantage Special Allocation Partnership Solution Set harnesses the complexity of partnerships by: Easily integrating operating models and production tax credits into partnership structures Balancing varying investor objectives based on equity contributions, partner interests, flipping shares, time horizon, etc. Providing reports on the foundational requirements for assessing “substantial economic effect” under IRC Section 704: - Capital accounts - Qualified income offsets - Deficit restoration obligations - Minimum gain - Non-recourse deductions - Minimum gain charge-backs - Contribution of assets per Sec. 704(c) Modeling Approach Advantage’s modeling approach facilitates the structuring, analysis, and management of even the most complex partnership types: This approach empowers users to analyze the consequences of partnership options. Compliance Manages capital accounts and minimum gain associated with “substantial economic effect” Handles contribution of appreciated assets per IRC section 704(c) Manages tax and accounting by using built-in tests and reports, e.g.: - Tax basis income effects - Hypothetical liquidation at book value for GAAP purposes Analytics Identifies optimal terms through automated searches Models and tracks the impact of ad-hoc allocations and timing of “flips” of partner interests Accommodates two, three, four, or more partners Combines multiple businesses or assets within partnership structures Ease of Use Simplifies modeling of special allocation partnerships for any business Design and modify structures with a drag-and-drop interface - Prompts to capture deal parameters - Capability to link to external spreadsheet data Includes partnership management reports Allows for easy customization of partnership structures The primary purpose of this product data sheet is to familiarize customers with the specific product offered by Advantage for Analysts (“Advantage”). Advantage does not represent or warrant the accuracy, adequacy, timeliness, completeness, or fitness for any particular purpose of the information contained herein, which is provided “as is”. Advantage does not provide tax, legal, or accounting advice, and accordingly, you should consult your own tax, legal, and accounting advisor before engaging in any transaction. Partnership Solution Components - Click Here