1. Topics

S Corporation, Partnership & LLC Taxation

Partner’s bonus was not a partnership distribution

A bonus payment to a hedge fund manager was payment for services outside her capacity as a partner.

How the death of a partner could affect a partnership’s year end

Partnerships must reevaluate their current fiscal year when a partner dies, since the estate may have a different year end than the individual partner.

Tax Court allows full meal deduction for NHL team’s away games

Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.

Allocating S corp. losses to acquiring and terminating shareholders

An S corporation’s election to use specific accounting can alter the allocation of passthrough items in some cases.

The importance of tracking AAA and E&P in transactions involving S corps.

Tracking these accounts is important if an S corporation enters into certain transactions such as redemptions, liquidations, reorganizations, or corporate separations.

New Sec. 987 regulations affect partnerships

The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.

Penalties for inconsistent reporting subject to deficiency procedures

Where there are no adjustments to partnership items, a taxpayer could not hide behind the Sec. 6230(a)(2)(A)(i) exclusion.

Temporary disguised-sale regulations raise concerns

Should the IRS consider recognizing a contributing partner’s economic risk of loss when the regulations are finalized?

A PATH to savings

This article examines the PATH act provisions and other developments favorable for taxpayers.

Boston Bruins can deduct full cost of meals for team’s away games

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.

Centralized partnership audit rules are reissued in proposed form

The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.

Final regs. address qualifying income exception for certain publicly traded partnerships

This item explains how the final regulations differ from the proposed regulations.

Recent regs. significantly change taxation of certain partnership contributions

Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.

The trust fund recovery penalty and LLCs

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.

Election to group activities for purposes of passive activity loss rules

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.

Sec. 743(b) adjustment complications in multitier partnerships

Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.

Losses disallowed where S corp. not indebted to shareholder

The Tax Court held that an S corporation shareholder could not claim losses from several wholly owned S corporations due to insufficient basis.

Tax Court upholds non-safe-harbor reverse like-kind exchange

The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring a reverse like-kind exchange intended to qualify for nonrecognition treatment.

S corporation owner-employees: Who controls income?

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.

Ordinary loss deductions under Sec. 165(g)(3) in the S corp. context

This item discusses whether S corporations should be entitled to an ordinary loss under Sec. 165(g)(3) as a matter of law.
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