TOSI rules generally apply to income that is assigned to non-active partners. If both parties are active in the business, TOSI wouldn't apply.
There's an excellent "decision tree" for TOSI on the Moodys Gartner site that you might find helpful: https://www.moodysgartner.com/wp-content/uploads/Moodys_Gartner_Tax_Law_Income-Sprinking-Flowchart.p...
TOSI rules generally apply to income that is assigned to non-active partners. If both parties are active in the business, TOSI wouldn't apply.
There's an excellent "decision tree" for TOSI on the Moodys Gartner site that you might find helpful: https://www.moodysgartner.com/wp-content/uploads/Moodys_Gartner_Tax_Law_Income-Sprinking-Flowchart.p...
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