General partners, doesn't necessarily imply active participation I don't believe. And I'm sure it doesn't imply material participation which is what you test for when determining passive vs active activities. General vs Limited partner role is more about who's taking more liability. More often than not, since the Gen.Partner is more liable he would want to be more hands-on, but he still has to pass the “material participation test.”
Each activity of the business is determined to be nonpassive or passive and defined in the General Partner's K-1, whereas for limited partners it's just summed up into one line for passive activities. Investment activities and deductions are individually listed as separate lines for both partners though. Activities are a key item to this whole idea: for our purposes it's just a set of similar(but distinguishable compared to other activities) operations. If half your business is renting and half is like sales, you can't group those together. Same goes for personal property rental and real estate rental. Each of those activities will be determined by the general partner to be active or passive. And in the case of non-real-estate pros, that real estate rental activities will always be passive for the partner, general or not.
WOWWWW! Major News: FICA and SE Taxes are NOT Income Taxes….sometimes stuff like this totally passes me by.
So…now to the point that made me spend hours only to come to that conclusion:
You're totally right about the guaranteed payments though. And more importantly the SE tax on the General Partner's share. They are considered payments for services rendered, i.e. employment, and that's what SE and FICA are taxing: Employment. Just spent so much time confused on that lol. I was like…where do partner's get taxed lol? Kinda like going through all this, it's helping me get the nitty gritty points such as that one lol.
Also because I'm on R3 and I don't want to move forward with reading =P. Learning through discovery is much better lool. Really need to push on though….9 days till test day…