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TOPICS / PASSTHROUGHS

Partnership and LLC Taxation

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.

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.

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.

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.

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.

IRS rules on cancellation of debt of a disregarded entity

Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.

TAX PRACTICE MANAGEMENT

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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.

Tax Clinic

IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects

IRS proposes using NAICS to determine lines of business for certain fringe benefit exclusions

IRS rules that community trust and affiliated nonprofit corporation can file a single Form 990

Prop. regs. issued on new qualified tips deduction

IRS rules for first time that REIT’s income from markup on electricity from EV charging stations is rents from real property