Level 15

Maybe but tax is just a part of the puzzle.

Guaranteed payments are payable without regard to the partnership's income.  The definition is codified under §707; you can't simply "treat" what is actually guaranteed payment in substance as a "distribution".

If there is a change to the arrangement in fact, the partnership agreement would have to be amended.  Would the partners be comfortable with not getting a certain sum if there is a drop in the partnership's income/profitability in the future?  How would that affect each of the partners?  How would the cash flow work out with the partnership and the partners?  Those are just some of the considerations.

Still an AllStar