Proposed regulations would extend to PFICs the aggregate treatment of U.S. partnerships and S corporations for Subpart F income.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
Disguised sale of a QOZ partnership interest
Several structural issues arise when a QOZ project involves using both private developer capital and third-party investor equity.
Passthrough-entity treatment of foreign subsidiary income
Entities such as S corporations and partnerships, as well as sole proprietorships, should carefully consider the U.S. tax treatment of foreign subsidiaries.
Partnership extraordinary-item treatment for accounting method adjustments
The regulations under Secs. 481(a) and 706 set forth rules governing a partnership’s treatment of accounting method changes and partner allocations but do not provide clear guidance on how income from an unfavorable Sec. 481(a) adjustment should be allocated among partners with varying interests during the four-year recognition period.
Single-member LLCs
A single-member limited liability company can adopt a variety of tax classifications to fulfill desired business purposes, besides conferring limited liability protection on its owner.
Ninth Circuit again addresses return filing
Faxing a return copy to an IRS agent or mailing it to an IRS attorney is not ‘filing’ the return.
Transfers of PTP interests: Options for foreign intermediaries
This item summarizes the options available to foreign intermediaries for transfers of PTP interests under current guidance and comments on some practical benefits and burdens of each.
Impact of business interest expense limitation regs. on partner redemptions
This item analyses two related examples of partner redemptions — with and without Sec. 163(j) basis adjustments — to highlight and clarify both the existing and new issues.
Nonresident alien partner’s gain on inventory items sourced to US
Nonresident alien’s Sec. 751 gain on sale of partnership interest was sourced to United States.
PTE deduction: Timing issues for accrual-method taxpayers
taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.
Navigating partnership continuations
This item discusses the rules and authorities related to partnership continuations and when they may apply.
Current developments in partners and partnerships
This article reviews and analyzes recent rulings and guidance involving partnerships. The discussion covers developments in the taxation of partnerships and partners, debt and income allocations, distributions, and basis adjustments.
Notice listing syndicated conservation easement transactions held invalid
Notice identifying syndicated conservation easement transactions as listed transactions is held invalid.
Dividing an LLC
The form of an LLC division determines the tax treatment of any resulting LLCs.
FinCEN provides time estimates for compiling beneficial ownership details
FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
FinCEN proposes rules about access to beneficial ownership information
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
Prop. regs. to provide withholding relief on sales of foreign PTPs
The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.
Final regs. issued on centralized partnership audit regime
Final regulations, issued last week, except certain partnership-related items from the regime and provide alternative rules for their examination by the IRS, as well as provide rules for the calculation of imputed underpayments.
Domestic filing exception requirements modified in draft Scheds. K-2, K-3
Revised draft instructions for partnership and S corporation Schedules K-2 and K-3 contain significant changes to the requirements to qualify for the domestic filing exception for filing and furnishing the 2022 schedules.
Real property losses are capital, not ordinary
In Musselwhite, T.C. Memo. 2022-57, the Tax Court held that a taxpayer’s losses from the sale of four lots (real property) were ordinary in nature, as opposed to capital.
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.
