Hawaii Revised Statutes

Haw. Rev. Stat. § 425-106 (2026)

  Governing law

✓ current as of July 2026
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     §425-106  Governing law.  (a)  Except as otherwise provided in subsection (b), the law of the jurisdiction in which a partnership has its chief executive office governs relations among the partners and between the partners and the partnership.

     (b)  The law of this State governs relations among the partners, and between the partners and the partnership, and the liability of partners for an obligation of a limited liability partnership. [L 1999, c 284, pt of §1; am L 2000, c 218, §5; am L 2004, c 121, §29]

 

Case Notes

 

  Partnership did not exist as a matter of law where plaintiff and defendant did not have an agreement to share profits; a $1.5 million release fee was interest on a loan and the loan commitment and accompanying letter did not evince an intent by the parties to share profits inasmuch as they lacked any language commonly utilized in partnership agreements, such as "partnership", "partner", "profits", and did not intimate any community of interest, or co-ownership, or sharing of profits, tending to show the relationship of partners.  111 H. 286, 141 P.3d 459 (2006).

 

 

Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1976–2021 · leading case: Fujimoto v. Au, 19 P.3d 699 (Haw. 2001).
Fujimoto v. Au, 19 P.3d 699 (Haw. 2001). · cites it 6× “425D, see supra note 10, they were, nevertheless, “partnerships” for purposes of the Uniform Partnership Act, see HRS § 425-106 (1993). 19 Inasmuch as *145 Kailua Partners and Kailua Estates were engaged in a joint venture with one another, as recited in Kailua Partners’…”
Shinn v. Edwin Yee, Ltd., 553 P.2d 733 (Haw. 1976). · cites it 4× “See HRS § 425-106. [2] Such an expenditure would have been far from being legitimate.”
Block v. Lea, 688 P.2d 724 (Haw. App. 1984). · cites it 4× “§ 425-106 but were not subject to the terms of the June 19, 1964, Partnership Agreement.”
Dang v. F & S Land Dev. Corp., 618 P.2d 276 (Haw. 1980). · cites it 2× “HRS § 425-106(1) reads: A partnership is an association (including a joint venture) of two or more persons to carry on as co-owners a business for profit.”
Buffandeau v. Shin, 587 P.2d 1236 (Haw. 1978). · cites it 2× “” HRS § 425-106(1). There are no specific indices of partnership, although an agreement to share in the profits and losses of a business is weighty evidence thereof.”
Stanford Carr Dev. v. Unity House, 141 P.3d 459 (Haw. 2006). “Hawai`i Revised Statutes (HRS) § 425-106 (1993), entitled "Partnership defined," provided that "[a] partnership is an association (including a joint venture) of two or more persons to carry on as co-owners a business for profit.”
In Re the Tax Appeal of O.W. Ltd. P'ship, 668 P.2d 56 (Haw. App. 1983). “See Hawaii Revised Statutes § 425-106(1) (1976). In order to constitute a partnership, there need be no partnership name nor any stipulation that there is a partnership.”
Swan v. Tanjuakio (D. Haw. 2021). · cites it 2× “] HRS § 425-106(a). And Hawaii’s partnership law is based on blackletter principles stemming from the Uniform Partnership Act.”
Tax Appeal of Wasson-Bendon Partners v. Kamikawa, 999 P.2d 865 (Haw. App. 2000). · cites it 3× “HRS § 425-106. 8. Taxpayer also has demonstrated that [T]axpayer participated in the management of MRC.”
— Haw. Rev. Stat. § 425-106(1) — 5 cases
Fujimoto v. Au, 19 P.3d 699 (Haw. 2001). “425D, see supra note 10, they were, nevertheless, “partnerships” for purposes of the Uniform Partnership Act, see HRS § 425-106 (1993). 19 Inasmuch as *145 Kailua Partners and Kailua Estates were engaged in a joint venture with one another, as recited in Kailua Partners’…”
Dang v. F & S Land Dev. Corp., 618 P.2d 276 (Haw. 1980). “HRS § 425-106(1) reads: A partnership is an association (including a joint venture) of two or more persons to carry on as co-owners a business for profit.”
Buffandeau v. Shin, 587 P.2d 1236 (Haw. 1978). “” HRS § 425-106(1). There are no specific indices of partnership, although an agreement to share in the profits and losses of a business is weighty evidence thereof.”
In Re the Tax Appeal of O.W. Ltd. P'ship, 668 P.2d 56 (Haw. App. 1983). “See Hawaii Revised Statutes § 425-106(1) (1976). In order to constitute a partnership, there need be no partnership name nor any stipulation that there is a partnership.”
Tax Appeal of Wasson-Bendon Partners v. Kamikawa, 999 P.2d 865 (Haw. App. 2000). “HRS § 425-106. 8. Taxpayer also has demonstrated that [T]axpayer participated in the management of MRC.”
— Haw. Rev. Stat. § 425-106(a) — 1 case
Swan v. Tanjuakio (D. Haw. 2021). “] HRS § 425-106(a). And Hawaii’s partnership law is based on blackletter principles stemming from the Uniform Partnership Act.”
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