The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
This item explains how the final regulations differ from the proposed regulations.
A responsible person may be subject to the TFRP if it can be shown he or she willfully failed to pay the trust fund taxes due.
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
The Tax Court held that an S corporation shareholder could not claim losses from several wholly owned S corporations due to insufficient basis.
The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring a reverse like-kind exchange intended to qualify for nonrecognition treatment.
The Tax Court held that a taxpayer had not elected to group two activities together under the passive activity loss rules simply by treating both activities as nonpassive.
Clients who wish to have income from services be treated as income of their corporations should have revise independent contractor agreements so that payments are made to their corporations.
Disposing of property related to a passive activity does not resolve all matters related to the property.
This item discusses whether S corporations should be entitled to an ordinary loss under Sec. 165(g)(3) as a matter of law.
Income earned by financial adviser was his, not the income of his wholly owned S corporation, and was therefore subject to self-employment tax.
The AICPA Task Force is developing a position paper with possible approaches that state CPA societies may want to consider in working with state legislatures and tax authorities in developing compliance policies.
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
This column focuses on what happens when a partnership’s business activities cease.
The IRS released a package of proposed provisions that will apply to the recently enacted centralized audit regime that generally assesses and collects tax at the partnership level.
Tax Court held that royalties received by an S corporation under a license agreement are taxable as ordinary income to the S corporation’s individual shareholder.
The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
A corporation may have to use the accrual method if it is required to maintain inventory records.
Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.