Passthroughs
The IRS issued proposed regulations on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests).
Aggregation may allow a taxpayer to claim a greater QBI deduction than if the wages and capital limitation was applied separately.
The IRS issued final regulations on the centralized partnership audit regime, which generally assesses tax at the partnership level.
This article discusses the new items practitioners should be aware of.
This article explains the tax implications of owning and selling an interest in a publicly traded partnership treated as a partnership and the tax reporting and compliance challenges that an investor in a PTP may face.
The TCJA fundamentally relaxed the rules on S corporation ownership by allowing nonresident aliens to be potential current beneficiaries of ESBTs and, therefore, indirect corporation shareholders.
Revoking an S election may be the best course in some cases, but timely filing and shareholder consent are required.
A note contributed to a partnership by an individual in exchange for an interest in the partnership was a bona fide debt.
Treasury never finalized the bulk of the regulations implementing Sec. 465, so reliance on proposed regulations issued in 1979 is the norm.
A timely election allows a married couple in business together to avoid the partnership filing rules.
This article lists the changes together, along with some unexpected nuances.
This update on recent developments in taxation relating to S corporations includes cases and rulings on eligible shareholders, electing small business trusts, inadvertent S election terminations, and other issues, as well as changes made by the TCJA.
Failure to properly complete all required fields on Form 8283, including the donor’s cost or other basis, could jeopardize the entire deduction with respect to the donated property.
A taxpayer’s conservation easement deductions were denied because the easements allowed for changes in the use of the property.
The IRS issued final regulations on the centralized partnership audit regime, which generally assesses tax at the partnership level.
This article reviews and analyzes recent rulings and decisions involving partnerships and discusses developments in partnership formation, debt and income allocations, distributions, and basis adjustments.
The IRS concluded that a taxpayer was not permitted to aggregate the S corporations with the partnership for the purpose of applying the at-risk rules of Sec. 465.
With the repeal of technical terminations, partnerships can only terminate for U.S. federal income tax purposes if no part of any business, financial operation, or venture continues to be conducted by any of its partners.
If the partnership agreement’s tax allocations do not have substantial economic effect, or if the partnership agreement is silent concerning tax allocations, the tax allocation must be made in accordance with the partners’ interests in the partnership.
This item discusses issues partnerships and their advisers should consider when designating a PR or DI, accounting for the potential for conflicts of interest, whether and to what extent limitations can be placed on the PR or DI, and how these roles differ dramatically from that of the TMP.
