S Corporations, Partnerships & LLCs - Contributions, Distributions & Basis

TOPICS / PASSTHROUGHS

August 1, 2019

Sec. 199A dividends paid by a RIC with interest in REITs and PTPs

The proposed regulations provided much-anticipated rules for RICs with REIT income for purposes of Sec. 199A.

May 1, 2019

Sec. 199A and the aggregation of trades or businesses

Aggregation may allow a taxpayer to claim a greater QBI deduction than if the wages and capital limitation was applied separately.

April 1, 2019

Publicly traded partnerships: Tax treatment of investors

This article explains the tax implications of owning and selling an interest in a publicly traded partnership treated as a partnership and the tax reporting and compliance challenges that an investor in a PTP may face.

April 1, 2019

Revisiting at-risk rules for partnerships

Treasury never finalized the bulk of the regulations implementing Sec. 465, so reliance on proposed regulations issued in 1979 is the norm.

April 1, 2019

Deduction allowed for partnership-related debt

A note contributed to a partnership by an individual in exchange for an interest in the partnership was a bona fide debt.

February 1, 2019

Current developments in partners and partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships and discusses developments in partnership formation, debt and income allocations, distributions, and basis adjustments.

February 1, 2019

IRS takes narrow view of aggregation under the at-risk rules

The IRS concluded that a taxpayer was not permitted to aggregate the S corporations with the partnership for the purpose of applying the at-risk rules of Sec. 465.

December 1, 2018

Using R&D credits to reduce payroll taxes: An overlooked opportunity for startups

This article discusses who qualifies to take the credit, how to make the election, the calculation and allocation of the credit, and how to report it.

October 1, 2018

Revisiting the application of Sec. 280G on partnerships and LLCs

Depending on how a taxpayer’s ownership is structured, the sale of a partnership interest can have a Sec. 280G impact on partners or members that are C corporations.

August 1, 2018

Withholding requirement on sale of partnership interest by foreign partners under the TCJA

This discussion gives a historical perspective of the treatment of the sale of a partnership interest and the changes enacted as part of the TCJA.

August 1, 2018

Lender Management LLC and its impact on investment partnerships

Lender Management contended that its activities met the test for an active trade or business under guidelines.

June 18, 2018

Disguised-sale partnership regs. withdrawn

The IRS announced that it was withdrawing temporary regulations on the treatment of partnership liabilities for disguised-sale purposes and proposing to reinstate the old rules.

May 1, 2018

3-year holding period applies to S corporations

The IRS announced that S corporations are subject to the new extended three-year holding period applicable to carried interests.

April 1, 2018

Understanding the new Sec. 199A business income deduction

The new deduction allows certain business owners to keep pace with the significant corporate tax cut provided by the Tax Cuts and Jobs Act.

April 1, 2018

The function of basis

A partner’s basis is key to determining the application of loss limitations and the recognition of gain or loss on partnership distributions and dispositions of partnership interests.

April 1, 2018