The act replaces the current TEFRA partnership audit rules and repeals the current special rules for electing large partnerships.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
Regulations Forthcoming on Partnership Nonrecognition of Property Contributions
The regulations would create an exception to the general nonrecognition rule for property contributions to a partnership in exchange for a partnership interest.
An Alternate Route to an IPO: Up-C Partnership Tax Considerations (Part 2)
This second article in a two-part series explores common tax considerations preceding and following an IPO employing an Up-C structure.
An Alternate Route to an IPO: The Up-C Partnership Structure (Part 1)
This first article in a two-part series covers the Up-C’s basic structure and how it is implemented.
Chief Counsel Advice Tackles Sec. 752’s Impact on Partnership COD Income
IRS Chief Counsel Advice interpreted whether Sec. 752 should be used to determine whether a
partnership’s debt is recourse or nonrecourse
for purposes of COD income rules.
Congress Makes Changes to Partnership Audit and Adjustment Rules
The new rules would apply to partnership returns filed for tax years beginning after Dec. 31, 2017.
IRS Proposes Rules on Disguised Payments for Services
The IRS issued proposed regulations that require a nonexclusive six-factor test to determine whether payments from a partnership to a partner are disguised payments.
Identifying a Partnership Distribution
A partnership distribution may consist of cash, property, or both. In addition, any reduction of a partner’s share of partnership liabilities is treated as an actual distribution of cash.
Extension OK Where Individual Had Apparent Authority to Sign It
A consent to extend the limitation period for the assessment for partnership items signed by the tax matters partner of a partnership in his capacity as the tax matters partner of another partnership was valid because the individual had the apparent authority to sign the consent.
Notice Contains Rules on Gain Recognition for Property Transferred to Foreign Partnerships
The IRS intends to issue regulations under Sec. 721(c) to ensure that a U.S. person recognizes gain either immediately or periodically when it transfers certain property to a partnership that has foreign partners related to the transferor.
Accounting for the Death of a Partner
This column reviews the income tax rules that come into play upon a partner’s death.
Special Care Needed in Dealing With Statute-of-Limitation Issues for TEFRA Partnerships
Audits of flowthrough entities such as partnerships cause administrative complexity for the IRS and taxpayers because the audit sometimes drags on longer than the statute-of-limitation period for the IRS to make an adjustment.
The Tax Adviser 2014 Best Article Award
James M. Greenwell received the award for his article on Sec. 704(c) Allocations.
Regulations Determine Partnership Distributive Shares When Ownership Changes
The IRS issued final regulations on determining partners’ distributive shares of partnership items when a partner’s interest varies during the partnership’s tax year.
Return Due Dates Changed in Highway Funding Bill
The short-term highway funding extension passed by the Senate contains several important tax provisions.
Attacking Transactions to Evade General Utilities Repeal
Temporary regulations prevent corporations from avoiding tax through the use of partnerships.
Proposed Rules Define Disguised Payments for Services in Partnerships
The IRS will apply a six-factor test to determine whether payments to partners are disguised payments for services under proposed regulations.
Reporting Information Regarding LLCs’ Passive Activities
Determining whether each individual member of an LLC materially participates requires assumptions that can pose problems.
Making a Valid Sec. 754 Election Following a Transfer of a Partnership Interest
It is not uncommon for a partnership to attempt to make a valid Sec. 754 election, only to find that it failed to satisfy regulatory requirements.
The Exclusion for Meals and Lodging
This article explains the general exclusion under Sec. 119(a) and the other limited exclusions for meals and lodging received from an employer and addresses whether a partnership may treat a partner as an employee for purposes of the Sec. 119(a) exclusion.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
