This article examines the PATH act provisions and other developments favorable for taxpayers.
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 a taxpayer had not elected to group two activities together under the passive activity loss rules simply by treating both activities as nonpassive.
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.
The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.
Changes in the the Bipartisan Budget Act of 2015 are a departure from how partnerships have been treated for federal income tax purposes.
The IRS issued three sets of regulations addressing issues of disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
The optional basis adjustment election is an attempt to allow partners to correct certain discrepancies by affecting a transferee’s allocable basis in the underlying partnership assets.
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.
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.