Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
S Corporation, Partnership & LLC Taxation
This item considers to what extent taxpayers may be able to apportion basis instead under Sec. 704(c) principles.
This item provides an overview of the division rules and touches on some key issues to consider when a transaction involves a partnership division.
The AICPA S Corporation Taxation Technical Resource Panel summarizes recent developments.
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.
An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.
Approval of an S election by the IRS and/or a state jurisdiction does not mean that S corporation status remains safe and sound forever.
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.
Generally, a trust cannot hold stock of an S corporation; however, grantor trusts, testamentary trusts, voting trusts, ESBTs, and QSSTs are permissible S corporation shareholders (Sec. 1361(c)(2)).
No deduction is allowed in the year of sale of a basketball team for deferred compensation owed to two of the team’s players.
This article compares the relative advantages and disadvantages of a QSST versus an ESBT in estate planning.
The IRS delays e-filing capability for schedules reporting S shareholders’ items of international tax relevance, earlier forecast for mid-June, to July 24.
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.
AAA and AE&P calculations are key to determining stock basis and, thus, the taxability of shareholder distributions.
S corporation stock was not subject to a substantial risk of forfeiture because the stock forfeiture provision was unlikely to be enforced.
The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.
The IRS, citing earlier problems e-filing a new form reporting S corporation owners’ basis, has granted relief to certain farmers and fishermen who missed their March 1 filing deadline.
Comment letters from the AICPA and state CPA societies also offer further recommendations.
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.
What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.