Advertisement
TOPICS / PASSTHROUGHS

Partnership and LLC Taxation

Carried interest reporting FAQs and guidance posted

The IRS posted FAQs with sample worksheets and instructions for taxpayers to use when calculating and reporting certain net long-term capital gains from partnership interests held in connection with the performance of services that must be recharacterized as short-term capital gains.

Navigating the new Schedules K-2 and K-3

Schedule K-2 will report the partnership/S corporation–level activity attached to a flowthrough return, while Schedule K-3 will be provided to each partner or shareholder and report its proportionate
amount for each item.

The Sec. 1061 capital interest exception and its impact on hedge funds

A hedge fund manager may be required to maintain separate tracking of a single partnership interest into several buckets to avoid the negative tax consequences of the short-term capital gain treatment of assets held from one to three years under Sec. 1061 for certain partnerships on the economic return of their invested capital.

When does a partnership terminate under Sec. 708?

It can be difficult to determine whether a partnership that retains de minimis assets or performs administrative functions during its winding-up period terminates, particularly if such activities cross tax years.

Using a family LLC for estate planning

LLCs can help families achieve key business and
tax objectives, while also providing liability protection and concentrating management power in
the hands of less than all of the owners.

Debt workouts involving commercial real estate

As short-term agreements that borrowers and creditors reached at the beginning of the pandemic start to expire, real estate companies and others
will need to find long-term solutions to their insolvency problem.

TAX PRACTICE MANAGEMENT

Image of happy, sad and neutral smiley faces.

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