The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
AICPA recommends simplified adjustment procedure in centralized partnership audits
The IRS should provide a simplified adjustment procedure for partnership audits, the AICPA recommended in a letter to the IRS Chief Counsel’s Office.
Allocating debt when a disregarded entity is a partner
The net value rule determines the extent to which a
partner who owns a partnership interest through a disregarded entity bears the economic risk of loss
for a partnership recourse liability.
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.
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.
A trap for the unwary: Sec. 743 in tiered partnerships
A taxpayer who pays the full FMV for a partnership interest that has forward Sec. 704(c) property associated with it and who subsequently contributes
it to another partnership may not receive the expected tax deductions.
IRS issues final regs. on electing out of centralized partnership audit regime
The regulations’ definition of an ‘eligible partner’ is key to determining whether a partnership can elect
out of the centralized partnership audit regime.
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 withdrawn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.
AICPA issues TQA on accounting for payments under the centralized partnership audit regime
The technical question and answer helps financial statement preparers account for the amount a partnership pays the IRS for previous underpayments of tax, interest, and penalties.
Appropriations act tax provisions include IRS funding and audit rules
The $1.3 trillion spending bill passed by Congress includes IRS funding and tax-related technical corrections, including changes to the centralized partnership audit regime.
AICPA recommends flexibility in partnership audits
The IRS should provide a simplified adjustment procedure for partnership audits, the AICPA recommended in a letter to the IRS Chief Counsel’s Office.
Proposed regs. would govern partnership audit adjustments
The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.
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.
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.
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.
Reporting publicly traded partnership Sec. 751 ordinary income and other challenges
Publicly traded partnerships can present challenges for
reporting.
Guidance addresses partnership accounting when IRS collects underpayments
A new technical question and answer from the AICPA provides nonauthoritative guidance to help financial statement preparers account for the amount a partnership pays the IRS under these circumstances.
Businesses affected by winter storms get extra time to file for extensions
The extension to March 20 applies to business taxpayers affected by the two recent winter storms, Quinn and Skylar, that primarily hit the Northeast and Mid-Atlantic United States.
Longer carried interest holding period includes S corporations
The IRS announced that the new three-year holding period for carried interests applies to S corporations as well as partnerships.
IRS issues final rules on election out of centralized partnership audits
IRS final regulations govern electing out of centralized
partnership audits.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
