Regulations streamline partnership basis elections
Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
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Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
For certain partners, the presumed preference for receiving a distributive share of income (including a priority profit allocation) may need further evaluation to determine how it coordinates with various international tax provisions.
A number of disqualifying events can terminate a corporation’s S status, and not all of those events are listed in the statute or immediately obvious.
This item discusses how depreciation recapture applies in certain situations involving partnerships.
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.
DEDUCTIONS
Business meal deductions after the TCJA
This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.
TAX RELIEF
Quirks spurred by COVID-19 tax relief
This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.