7909 / What is a cattle breeding program?

Traditional breeding programs involve the purchase of a herd of breeding cattle (either beef or dairy cattle) that is managed by a firm specializing in breeding. Male offspring (steer calves) are generally sold for ordinary income each year, but female calves (heifers) are usually kept (unless they are unsuitable) in order to expand the herd.

Embryo transplant technology has resulted in a form of breeding program called a “Super Cow” program. These ventures involve the purchase of several prize breeding cows (each may cost in excess of $150,000) along with a herd of “recipient” cows that have inferior bloodlines. The donor (or “super”) cows are artificially inseminated and the resulting embryos are transplanted into the recipient cows. Donor cows are superovulated so that they produce more eggs for fertilization than they would normally. A donor cow can thus produce multiple offspring in one year rather than the one that would be produced naturally. Recipient cows usually have little value aside from the embryo they carry. Some programs lease recipient cows from another party until the resulting calves are weaned. Embryo transplant operations are much more expensive to manage than the traditional form of breeding program.

Many programs will use technology without purchasing super cows by combining direct breeding with artificial insemination and the purchase of superior embryos, often leasing recipient cows in order to decrease capital expenditures and increase deductions.

Breeding operations are usually carried on by limited partnerships, but S corporations, joint ventures, and direct ownership are also used. Some super cow programs are formed as tenancies-in-common in which an individual investor owns an undivided fractional interest in one or several cows and the investor receives income or is allocated losses based on fractional interest. Generally, limited partnerships and S corporations act as flow-through entities, and partners and shareholders report their share of the entity’s income, deductions, and credits on their own tax returns (see Q 7732). (Electing large partnerships have somewhat different flow-through rules than regular partnerships (see Q 7733).) However, if a publicly traded partnership is taxed as a corporation, the income, deductions, and credits are reported by the partnership and do not flow through to the partners. Electing 1987 partnerships are subject to both an entity level tax and the flow-through rules. In general, investment in a publicly traded partnership taxed as a corporation will be taxed as an investment in a corporation. See Q 7728 for the treatment of publicly traded partnerships.