What you have is a little unusual. Usually a guaranteed payment means a partner or partners gets a fixed amount before the other partners participate in the profits of the partnership. This has an effect on the income distributable to the partners. The way a partnership works is the partnership determines its taxable income and other tax attributes and these are distributed based on each partners' partnership percentage. This is their income and what they pick up on their tax return. The actual distributions to a partner in cash have nothing to do with their taxable income but they do decrease their basis in their partnership investment. Basis is also increased by taxable income and reduced by tax losses. A partners guaranteed payment is taxable to them and reduces the partnership's taxable income by a similar amount. The net amount after this (income or loss) is distributable to the partners. These are quick and dirty explanations. If their basis becomes negative this could limit the partnership losses a partner can deduct. Cash distributions have nothing to do with a partner's taxable income. I think what you really have is a agreement to share the income and cash distributions. A guaranteed payment to a partner usually means he gets paid no matter what even if the partnership has no cash and borrows the money. I don't think this is what you have. If you say you have a guaranteed payments you are each 100% taxable on what you were paid and this would reduce the partnership's taxable income by a similar amount. If he partnership has income or a loss after this deduction for the guaranteed payments this is split among the partners in however manner they share in the income. Taxable income for each partner would be the same whether you treated their distribution as a guaranteed payment or just picked up the income before the guaranteed payments. I am afraid that the treating the distributions as guaranteed payments might increase the partners self employment tax since the whole amount would be self employment income to them. This treatment is determined on the partnership Form 1065 that is filed.. I think you don't really have a guaranteed payment but have simply agreed as to how to distribute cash from the partnership. I would treat these payments as distributions and pick up each partners' share of taxable income before the distributions on the Schedule K-1 filed by the partnership.
What you are doing by treating them as guaranteed payments would only be appropriate if you had other partners. Partnerships are extremely complex and I advise anyone who has one to consult with a tax professional who has a great deal of experience with partnerships when filing their tax return.
