When an LLC has two or more members, the IRS will automatically treat it as a partnership.

I need some advice on structuring an equity partnership for a development that I'm planning to build. 

I know people preach partnerships and I will probably get beat up (more than I am already) about this, but I'm solely responsible for my wealth.

If your plan involves taking you below that threshold, then it is not sound, and should not even be considered.As an example to others considering partnerships: this is a classic example of the problem with poorly structured partnerships. 

Shares of stock or membership interests in an LLC/partnership are not like-kind with real property, so if the syndication is set up where they are purchasing stock/membership interests, then a 1031 wouldn’t work.

Hey Biggerpockets fam,In my job, I network with a lot of real estate professionals around the Cincinnati area and try to help them connect with other mutually beneficial partnerships (investors, agents, lenders, PM's, etc).Today I had an agent call me desperately in need of a rental.

They prefer not to have any partnership contracts in place, stating they only do handshake/verbal deals with all of their clients.

Micheal Let me know If I am getting this wrong If you used the borrowed fund to acquire the limited partnership interest, then the interest expense will be characterized as passive, and if not limited by passive loss limitation, it will be reported in the Schedule E.This is better and correct way of treating the interest expense as you dont lose the deduction if you don't itemize the deduction at personal level.  

Instead of employing a third party, you may want to consider partnering with an experienced operator as a JV partnership on this deal.  

Based upon my experience, you are already acting as a sole proprietorship (or partnership with your wife) in the eyes of the IRS regardless of the existence of a legal business entity.