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.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
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 withdrawn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.
Partnership audit adjustments addressed in proposed regs.
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.
Providing services to a partnership in bankruptcy
Before a partnership files for bankruptcy, a financial professional should assess the nature of its debts.
Current developments in partners and partnerships
This article reviews and analyzes recent law changes as
well as rulings and decisions involving partnerships.
IRS reallocates losses of joint venture among foreign and domestic partners
A CCA memorandum addressed the allocation of partnership losses where certain partners had negative capital account balances.
Final rules govern election out of centralized partnership audits
The IRS finalized the rules for determining whether partnerships are eligible to elect out of the centralized audit procedures enacted in 2015, which apply to partnerships this year.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
