This item discusses how to request modification of an imputed underpayment.
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TOPICS / PASSTHROUGHS
Partnership and LLC Taxation
Self-employment tax and LLCs
An LLC member’s distributive share of LLC income and loss from a trade or business is generally subject to self-employment tax, raising several issues around guaranteed payments, retirement payments, rental income, and members who are employees of the LLC.
Questions to consider before electing into a PTE tax
Twenty-nine states have enacted a passthrough entity tax as a possible workaround to the federal state and local tax deduction cap.
Regulations streamline partnership basis elections
Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
Meaning of ‘filed’ defined for purposes of delinquent partnership returns
Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;
State PTE elections: A big picture perspective
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
Depreciation recapture in the partnership context
This item discusses how depreciation recapture applies in certain situations involving partnerships.
Guaranteed payments vs. distributive share of income
For certain partners, the presumed preference for receiving a distributive share of income (including a priority profit allocation) may need further evaluation to determine how it coordinates with various international tax provisions.
Nonliquidating distributions: Ways to determine basis
This item considers to what extent taxpayers may be able to apportion basis instead under Sec. 704(c) principles.
A practical guide to partnership division planning
This item provides an overview of the division rules and touches on some key issues to consider when a transaction involves a partnership division.
Tennessee taxation of passthrough entities
An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.
Payments to LLC members for services
When LLC members receive payments for services performed for the LLC, the tax treatment depends on whether the member is performing the services in the capacity as a member.
State tax considerations around the sale of a partnership interest
This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.
Deferred compensation not deductible in year basketball franchise sold
No deduction is allowed in the year of sale of a basketball team for deferred compensation owed to two of the team’s players.
More Schedule K-2 and K-3 FAQs posted
In eight new FAQs on its website, the IRS covers some special issues, including several that it says will be added to the forms’ instructions.
BBA partnership audits show high no-change rate, TIGTA says
The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.
AICPA again asks IRS to delay K-2/K-3 reporting
Comment letters from the AICPA and state CPA societies also offer further recommendations.
IRS offers further K-2/K-3 relief
The new schedules for returns of passthrough entities with international items have been greeted with antipathy by practitioners. The IRS provided relief Wednesday for eligible entities for tax year 2021.
Complying with new schedules K-2 and K-3
What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.
Reporting aspects of Sec. 743(b) adjustments
Partnerships and their partners need to work closely to maintain strong communications to overcome challenges to information sharing and, ultimately, to computational matters and information reporting.
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.
