Usually, the Board of Directors hire a manager, and management is centralized. It should be noted that all of the business forms have such options as paying rent as distributions to owners that rent land to the entity. Special allocations are possible. Minimizing the tax burden under these complex circumstances can lead to elaborate and cumbersome models involving numerous business forms. Built-in gains and passive net income are taxed at entity level.
Income is taxed at the corporate and shareholder levels.
Converting from partnership to higher level structures entails no associated capital gains. Preferable to the LLC if converting from a C corporation. No adjustment in the basis of assets when there is a transfer of ownership. In general, a balance must be struck between the maintaining flexibility of individual owners while ensuring stability of the joint venture for remaining owners. The best fit, again, will depend on the particular situation.