The changes affect not only procedural rules and technicalities, but also the underlying economic valuation of partnership interests and legal rights of partners as well.
New regulations provide rules for determining who is the “taxpayer” for purposes of applying the Sec. 108 discharge-of-indebtedness rules to a grantor trust or disregarded entity.
This item examines whether a bad-boy guarantee changes an otherwise nonrecourse liability to a recourse liability.
The IRS issued rules regarding the time, manner, and form for partnerships to make the election to apply the recently enacted unified partnership audit rules for certain years before Jan. 1, 2018.
Property transfers between a partner and a partnership are considered to be a taxable sale of the property under certain circumstances.
Regulations governing the federal income tax consequences of a partnership merger lack clear guidance on when a transaction resulting in the combination of two partnerships into a single partnership constitutes a merger.
This article analyzes new rules regarding the audit procedures for partnerships and describes important elections partnerships may make.
The IRS issued temporary regulations intended to halt the practice of treating partners as employees of a disregarded entity in order to include them in employee benefit plans.
The IRS should consider expanding the list of revaluation events to include additional transactions that change the underlying economics of the partners’ arrangement, if a reliable FMV for the revalued assets can be established.
The IRS finalized regulations that provide rules for determining who is the “taxpayer” for purposes of applying the Sec. 108 discharge-of-indebtedness rules to a grantor trust or disregarded entity.
Rules regarding gain or loss on liquidation are a major reason for formation as an LLC rather than as a corporation.
The IRS issued temporary regulations clarifying that partners in a partnership that owns a disregarded entity cannot be treated as employees of the disregarded entity.
Taxing authorities have sought to incorporate adequate lead time into the tax filing process.
Temporary regulations issued by the IRS amend an existing safe harbor that is used for determining whether allocations of CFTEs are deemed to be in accordance with the partners’ interests in the partnership.
There are risks are associated with valuing carried interest transfers.
If the general partner has unfettered discretion to make or withhold distributions, any gift of an interest in the partnership may be treated as a gift of a future interest not qualifying for the annual gift tax exclusion.
The IRS requested comments on several issues to assist it in issuing regulations to implement the new rules for partnership audits that were passed by Congress last year to replace the long-standing TEFRA audit regime.
New rules released by the IRS are intended to improve an existing safe harbor for allocating creditable foreign taxes so that they are deemed to be in accordance with the partners’ interests in the partnership.
This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.
The Bipartisan Budget Act of 2015 greatly strengthened the IRS’s ability to examine certain partnerships.