1. Topics

S Corporation, Partnership & LLC Taxation

2015 Budget Act Makes Big Changes to Partnership Audit Procedures

The act replaces the current TEFRA partnership audit rules and repeals the current special rules for electing large partnerships.

Regulations Forthcoming on Partnership Nonrecognition of Property Contributions

The regulations would create an exception to the general nonrecognition rule for property contributions to a partnership in exchange for a partnership interest.

An Alternate Route to an IPO: Up-C Partnership Tax Considerations (Part 2)

This second article in a two-part series explores common tax considerations preceding and following an IPO employing an Up-C structure.

Calculating Basis in Debt

Direct shareholder loans to an S corporation can be very important tools for tax planning.

An Alternate Route to an IPO: The Up-C Partnership Structure (Part 1)

This first article in a two-part series covers the Up-C’s basic structure and how it is implemented.

Chief Counsel Advice Tackles Sec. 752’s Impact on Partnership COD Income

IRS Chief Counsel Advice interpreted whether Sec. 752 should be used to determine whether a partnership’s debt is recourse or nonrecourse for purposes of COD income rules.

Congress Makes Changes to Partnership Audit and Adjustment Rules

The new rules would apply to partnership returns filed for tax years beginning after Dec. 31, 2017.

IRS Proposes Rules on Disguised Payments for Services

The IRS issued proposed regulations that require a nonexclusive six-factor test to determine whether payments from a partnership to a partner are disguised payments.

Identifying a Partnership Distribution

A partnership distribution may consist of cash, property, or both. In addition, any reduction of a partner’s share of partnership liabilities is treated as an actual distribution of cash.

Extension OK Where Individual Had Apparent Authority to Sign It

A consent to extend the limitation period for the assessment for partnership items signed by the tax matters partner of a partnership in his capacity as the tax matters partner of another partnership was valid because the individual had the apparent authority to sign the consent.

Should S Corporations Get Ordinary Loss Treatment for Losses on Subsidiary Stock?

The question of whether an S corporation should be treated the same as a C corporation when its subsidiary corporation is insolvent has not been definitively answered.

Notice Contains Rules on Gain Recognition for Property Transferred to Foreign Partnerships

The IRS intends to issue regulations under Sec. 721(c) to ensure that a U.S. person recognizes gain either immediately or periodically when it transfers certain property to a partnership that has foreign partners related to the transferor.

Accounting for the Death of a Partner

This column reviews the income tax rules that come into play upon a partner’s death.

Special Care Needed in Dealing With Statute-of-Limitation Issues for TEFRA Partnerships

Audits of flowthrough entities such as partnerships cause administrative complexity for the IRS and taxpayers because the audit sometimes drags on longer than the statute-of-limitation period for the IRS to make an adjustment.

The Tax Adviser 2014 Best Article Award

James M. Greenwell received the award for his article on Sec. 704(c) Allocations.

Regulations Determine Partnership Distributive Shares When Ownership Changes

The IRS issued final regulations on determining partners’ distributive shares of partnership items when a partner’s interest varies during the partnership’s tax year.

Return Due Dates Changed in Highway Funding Bill

The short-term highway funding extension passed by the Senate contains several important tax provisions.

Attacking Transactions to Evade General Utilities Repeal

Temporary regulations prevent corporations from avoiding tax through the use of partnerships.

Proposed Rules Define Disguised Payments for Services in Partnerships

The IRS will apply a six-factor test to determine whether payments to partners are disguised payments for services under proposed regulations.

Is It Rent? That Depends on the Lease

A recent Tax Court decision sheds light on the importance of lease terms to determine what is rent and how Sec. 467 may apply to advance rents.
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