1. Topics

S Corporation, Partnership & LLC Taxation

Disposing of passive activities

Disposing of property related to a passive activity does not resolve all matters related to the property.

State Challenges With the New Federal Partnership Audit Rules

The AICPA Task Force is developing a position paper with possible approaches that state CPA societies may want to consider in working with state legislatures and tax authorities in developing compliance policies.

Failure to Use S Corporation Correctly Results in Self-Employment Tax

Income earned by financial adviser was his, not the income of his wholly owned S corporation, and was therefore subject to self-employment tax.

Planning for the Discontinuation of a Partnership’s Business

This column focuses on what happens when a partnership’s business activities cease.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.

Centralized Partnership Audit Rules Proposed

The IRS released a package of proposed provisions that will apply to the recently enacted centralized audit regime that generally assesses and collects tax at the partnership level.

Royalties on Pharmaceutical Technology Taxable as Ordinary Income, Tax Court Holds

Tax Court held that royalties received by an S corporation under a license agreement are taxable as ordinary income to the S corporation’s individual shareholder.

IRS Rules Govern Disguised Sales and Allocations of Partnership Liabilities

The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.

Avoiding Conversion to the Accrual Accounting Method by Electing S Status

A corporation may have to use the accrual method if it is required to maintain inventory records.

Basis for “Bad Boys”

Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.

New Partnership Audit Procedures Will Have a Profound Impact

Changes in the the Bipartisan Budget Act of 2015 are a departure from how partnerships have been treated for federal income tax purposes.

Disguised-Sale and Partnership Liability Allocation Rules Issued

The IRS issued three sets of regulations addressing issues of disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.

Advantages of an Optional Partnership Basis Adjustment

The optional basis adjustment election is an attempt to allow partners to correct certain discrepancies by affecting a transferee’s allocable basis in the underlying partnership assets.

IRS Provides Rules for Early Election of New Partnership Audit Procedures

The IRS issued rules regarding the time, manner, and form for partnerships to make the election to apply the recently enacted unified partnership audit rules for certain years before Jan. 1, 2018.

A Glimpse Into the New Partnership Audit Rules

The changes affect not only procedural rules and technicalities, but also the underlying economic valuation of partnership interests and legal rights of partners as well.

Asset Acquisition Target Ineligible for Success-Based Fee Safe Harbor

Recent Chief Counsel Advice provides helpful insight to taxpayers planning or negotiating merger and acquisition transactions.

Violating Certain “Bad Boy” Guarantees Can Trigger Recourse Liabilities

This item examines whether a bad-boy guarantee changes an otherwise nonrecourse liability to a recourse liability.

How the COD Rules Apply to Grantor Trusts and Disregarded Entities

New regulations provide rules for determining who is the “taxpayer” for purposes of applying the Sec. 108 discharge-of-indebtedness rules to a grantor trust or disregarded entity.

Top 10 Easy Ways That Trusts Cause Loss of S Corporation Status

This item presents 10 ways that S corporations can lose their S election status, most of them involving trusts.

Documenting Deductible Transaction Costs for Acquisitive Transactions

This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc. 2011-29.
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