Skip to main content
Level 1
February 17, 2020

Partnership paid royalties to partners

  • February 17, 2020
  • 1 reply
  • 5 views

I have a partnership that pays out royalties to individuals.  Some of these individuals are the partners themselves.  Are these payments to partners guaranteed payments for services?  

    This topic has been closed for replies.

    1 reply

    Level 4
    February 21, 2020

    Rev Rul 81-178, "To be a royalty, a payment must relate to the use of a valuable right."  The payment of royalties, by that definition is not a payment for services, and so cannot meet the definition of a guaranteed payment for services.