Passthroughs
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.
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.
Qualified business income deduction regs. and other guidance issued