A bonus payment to a hedge fund manager was payment for services outside her capacity as a partner.
Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.
Partnerships must reevaluate their current fiscal year when a partner dies, since the estate may have a different year end than the individual partner.
Tracking these accounts is important if an S corporation enters into certain transactions such as redemptions, liquidations, reorganizations, or corporate separations.
An S corporation’s election to use specific accounting can alter the allocation of passthrough items in some cases.
Should the IRS consider recognizing a contributing partner’s economic risk of loss when the regulations are finalized?
Where there are no adjustments to partnership items, a taxpayer could not hide behind the Sec. 6230(a)(2)(A)(i) exclusion.
The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
This article examines the PATH act provisions and other developments favorable for taxpayers.
The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.
The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
This item explains how the final regulations differ from the proposed regulations.
A responsible person may be subject to the TFRP if it can be shown he or she willfully failed to pay the trust fund taxes due.
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
The Tax Court held that an S corporation shareholder could not claim losses from several wholly owned S corporations due to insufficient basis.
The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring a reverse like-kind exchange intended to qualify for nonrecognition treatment.
The Tax Court held that a taxpayer had not elected to group two activities together under the passive activity loss rules simply by treating both activities as nonpassive.
Clients who wish to have income from services be treated as income of their corporations should have revise independent contractor agreements so that payments are made to their corporations.
Disposing of property related to a passive activity does not resolve all matters related to the property.