Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
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.
A Glimpse Into the New Partnership Audit Rules
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.
Violating Certain “Bad Boy” Guarantees Can Trigger Recourse Liabilities
This item examines whether a bad-boy guarantee changes an otherwise nonrecourse liability to a recourse liability.
How the COD Rules Apply to Grantor Trusts and Disregarded Entities
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.
IRS Issues Temporary Regulations on Early Elections 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.
Recognizing When a Disguised Sale of Property Takes Place
Property transfers between a partner and a partnership are considered to be a taxable sale of the property under certain circumstances.
Partnership Audit Rules for the Next Decade
This article analyzes new rules regarding the audit procedures for partnerships and describes important elections partnerships may make.
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.
