Passthroughs
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.
Shareholders and their advisers should be prepared to verify the validity of the S election when the decision is made to begin marketing the company
for sale.
The IRS is permitting certain partnerships that timely filed their tax returns for the 2018 tax year an extension of time to file superseding returns and Schedules K-1 for their partners.
This item provides a brief overview of the BBA audit regime and discusses some of the practical considerations that partners may want to keep in
mind when buying or selling partnership interests.
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).
Converting a C corporation to a limited liability company can sometimes be beneficial, but the tax
consequences must be planned for.
The IRS ruled that a distribution to the sole shareholder of a C corporation was partly a recovery of the former S corporation’s accumulated adjustments account (AAA) and a taxable dividend for the remaining distribution.
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.
Traps for the unwary: Tax Cuts and Jobs Act changes
Qualified business income deduction regs. and other guidance issued