REG Partnerships · Updated November 2026

Inside Basis vs Outside Basis in a Partnership

Inside and outside basis measure different things and can diverge.

Inside basis

Inside basis is the partnership's tax basis in its underlying assets.

Outside basis

Outside basis is an individual partner's tax basis in the partnership interest.

Why they differ

Contributions, distributions, liabilities, purchases of partnership interests, and special basis adjustments can create differences.

Exam strategy

Ask whose basis the question wants: partnership asset basis or partner interest basis.

The takeaway

Inside basis belongs to partnership assets; outside basis belongs to the partner's partnership interest.

Related Summit resources

FAQ

What is the core idea?

Inside basis belongs to partnership assets; outside basis belongs to the partner's partnership interest.

What should you identify first?

Inside and outside basis measure different things and can diverge.

Why does this matter on the CPA Exam?

Separate the partnership's basis in its assets from each partner's basis in the partnership interest.