The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
Penalties for inconsistent reporting subject to deficiency procedures
Where there are no adjustments to partnership items, a taxpayer could not hide behind the Sec. 6230(a)(2)(A)(i) exclusion.
Temporary disguised-sale regulations raise concerns
Should the IRS consider recognizing a contributing
partner’s economic risk of loss when the regulations are finalized?
A PATH to savings
This article examines the PATH act provisions and other developments favorable for taxpayers.
Centralized partnership audit rules are reissued in proposed form
The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
Final regs. address qualifying income exception for certain publicly traded partnerships
This item explains how the final regulations differ from the proposed regulations.
Recent regs. significantly change taxation of certain partnership contributions
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
The trust fund recovery penalty and LLCs
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.
Election to group activities for purposes of passive activity loss rules
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.
Sec. 743(b) adjustment complications in multitier partnerships
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
State Challenges With the New Federal Partnership Audit Rules
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.
Planning for the Discontinuation of a Partnership’s Business
This column focuses on what happens when a partnership’s business activities cease.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Centralized Partnership Audit Rules Proposed
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.
IRS Rules Govern Disguised Sales and Allocations of Partnership Liabilities
The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
Basis for “Bad Boys”
Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.
New Partnership Audit Procedures Will Have a Profound Impact
Changes in the the Bipartisan Budget Act of 2015 are a departure from how partnerships have been treated for federal income tax purposes.
Disguised-Sale and Partnership Liability Allocation Rules Issued
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.
Advantages of an Optional Partnership Basis Adjustment
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.
IRS Provides Rules for Early Election of New Partnership Audit Procedures
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.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
