Passthroughs
This discussion provides a review of the federal filing requirements for amending partnership returns and focuses on three states that have taken varying approaches to address the corresponding state effects of the BBA.
This article explains the procedures for making adjustments to previously filed partnership returns, a process that changed significantly with the creation of the centralized partnership audit regime.
This annual update on S corporations covers cases, regulations, and IRS rulings that have been issued in the last year, including the rules for eligible terminated S corporations.
In highly leveraged partnerships, bottom-dollar payment obligations have been used by partners to increase their at-risk basis in a partnership to use loss allocations or to receive nontaxable cash distributions.
This item discusses final regulations providing guidance on when partnership liabilities are recognized as recourse under Sec. 752.
An entity that is recognized for federal tax purposes as an entity separate from its owners can be classified as one of several entity types, but the available classification options depend greatly on
state law and the number of owners or members.
Federal tax reform has caused additional states to consider passthrough-entity-level taxes.
A recent Tax Court case provides a road map for establishing the legal requirements needed to sustain a deduction for worthlessness, and reinforces the position that actual abandonment of a partnership interest is not required to claim a loss under Sec. 165(a).
To allow those partnerships to take advantage of the beneficial tax provisions in the Coronavirus Aid, Relief, and Economic Security Act, the IRS is allowing partnerships to file amended returns for 2018 or 2019.
A limited liability company can elect to be classified as a corporation and elect S status by following the procedures discussed here.
This item discusses the authority to consider when determining whether the general partner of an investment fund is engaged in a Sec. 162 trade or business.
The enactment of the Sec. 199A QBI deduction adds a new consideration to the form of entity analysis because the QBI deduction available to a business owner may vary depending on a business’s entity form. This article discusses the differences in calculating the QBI deduction for S corporations and LLCs in a variety of scenarios.
To promote nationwide consistency, the AICPA encourages states’ adoption of the MTC model statute that conforms to the new federal partnership audit regime.
The IRS published two memoranda that clarify how it will implement the BBA procedures, including appeal rights.
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.
