Intercompany transactions do not increase debt basis in S corporation
Loans among related entities were not bona fide indebtedness that would give rise to debt basis in an S corporation for the shareholder.
Passthroughs
The function of basis
A partner’s basis is key to determining the application of loss limitations and the recognition of gain or loss on partnership distributions and dispositions of partnership interests.
Reporting publicly traded partnership Sec. 751 ordinary income and other challenges
Publicly traded partnerships can present challenges for reporting.
Converting from S corp. to C corp.: Select issues for consideration
As a result of tax reform, which provides for a significant decrease in the corporate tax rate and a more modest decrease in passthrough tax rates, business owners may consider revoking S corporation elections.
Guidance addresses partnership accounting when IRS collects underpayments
A new technical question and answer from the AICPA provides nonauthoritative guidance to help financial statement preparers account for the amount a partnership pays the IRS under these circumstances.
Businesses affected by winter storms get extra time to file for extensions
The extension to March 20 applies to business taxpayers affected by the two recent winter storms, Quinn and Skylar, that primarily hit the Northeast and Mid-Atlantic United States.
Longer carried interest holding period includes S corporations
The IRS announced that the new three-year holding period for carried interests applies to S corporations as well as partnerships.
IRS issues final rules on election out of centralized partnership audits
IRS final regulations govern electing out of centralized partnership audits.
Partnership audit adjustments addressed in proposed regs.
The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.
Current developments in partners and partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Providing services to a partnership in bankruptcy
Before a partnership files for bankruptcy, a financial professional should assess the nature of its debts.
Dispute between shareholders did not strip taxpayers of beneficial rights of ownership
The Tax Court held that the taxpayers’ poor relations with other shareholders of an S corporation did not affect their ownership interest in the corporation.
IRS reallocates losses of joint venture among foreign and domestic partners
A CCA memorandum addressed the allocation of partnership losses where certain partners had negative capital account balances.
Final rules govern election out of centralized partnership audits
The IRS finalized the rules for determining whether partnerships are eligible to elect out of the centralized audit procedures enacted in 2015, which apply to partnerships this year.
Tax Court holds microcaptive insurance company was not a bona fide insurer
Tax Court held that amounts passthrough business entities paid to a purported insurance company they owned were not premiums paid for insurance contracts and not deductible.
IRS holds investment transaction is sale of refined coal tax credits
Investors in a partnership were not entitled to deduct credits because the investment transaction was structured solely to facilitate the purchase of the credits.
Items and factors to consider in setting reasonable compensation
All companies should maintain supporting documentation for payments.
IRS will not acquiesce to ruling on non-safe-harbor reverse Sec. 1031 exchange
IRS announced it will not acquiesce to a Tax Court ruling in which it held that a taxpayer’s disposition and acquisition of property was not a self-exchange and qualified for Sec. 1031 nonrecognition treatment.
Lack of economic substance dooms loss deductions
A taxpayer was not entitled to a passthrough loss from the dissolution of an S corporation because the dissolution was part of a tax structure that did not have economic substance.
Proposed regulations would allow Sec. 754 election without partner’s signature
To ease the regulatory burden on partnerships, the IRS announced that it is eliminating the requirement that partnership elections under Sec. 754 be signed by a partner.
