The IRS published two memoranda that clarify how it will implement the BBA procedures, including appeal rights.
To promote nationwide consistency, the AICPA encourages states’ adoption of the MTC model statute that conforms to the new federal partnership audit regime.
This article discusses developments in the taxation of partnerships and partners, debt and income allocations, distributions, and basis adjustments.
This item discusses the tax basis and partnership capital accounting impacts of partner-incurred syndication costs.
Buy/sell agreements allow LLC members to control the transfer of ownership upon the occurrence of certain triggering events, but they must be carefully structured.
The IRS recently released new draft forms for partnerships under the centralized partnership audit regime enacted by the Bipartisan Budget Act.
The IRS is postponing the requirement to report partners’ shares of partnership capital on the tax-basis method for 2019 (for partnership tax years beginning in calendar 2019) until 2020 (for partnership tax years that begin on or after Jan. 1, 2020).
Review how shareholders would be taxed on the gain from the sale of stock in an S corporation that is not affected by the built-in gains tax.
Partnerships making guaranteed payments may want to consider restructuring them as priority profit allocations.
A taxpayer, who received interests in four partnerships from his father by gift or bequest, did not step into his father’s shoes with respect to interest on certain partnership loans,
The TCJA provides a way to avoid the unexpected termination of the S election when certain ESBT situations occur.
A tax court recently found that where an S corp. and affiliated entities were partially owned by a taxpayer, payment of the S corp.’s expenses by the affiliated entities did not increase the taxpayer’s debt basis in the S corporation.
The IRS agreed with the team’s position that the amounts received for the memberships do not constitute income because the team is obligated to repay the money to the “members.”
Consider the scenarios that could cause a partnership to terminate so appropriate steps can be taken to properly account for the business’s status change.
This discussion focuses on the withholding regime under the proposed regulations applicable to non-publicly traded partnerships and highlights a number of compliance and practical implications.
A practitioner who is a true trusted business adviser should consider what the business owner wants to achieve when making this decision.
Partnerships will need to establish procedures to deal with secondary withholding in the event that transferees do not withhold or collect the appropriate documentation.
A special relief provision allows unused losses caused by a lack of basis to be deducted by an S corporation shareholder under certain conditions for one year (or more) during the S corporation’s post-termination transition period.
The proposed regulations provided much-anticipated rules for RICs with REIT income for purposes of Sec. 199A.
The BBA rules that allow a third party to act on behalf of the partnership, as well as the change in IRS adjustments being assessed at the partnership level, bring significant new challenges for tax practitioners.