1. Topics

S Corporation, Partnership & LLC Taxation

IRS Issues Regs. on Interest Expense Allocation and Apportionment for Partners

The IRS has issued temporary and proposed regulations that make four changes to the rules for allocating and apportioning interest expense for partners in partnerships.

Regs. Issued on Transfers of Partnership Interest to Satisfy Partnership Debt

The IRS issued final regulations on the application of Sec. 108(e)(8) to partners and partnerships.

Excise and Employment Tax Treatment of Disregarded Entities Clarified

The IRS issued final regulations clarifying the treatment of disregarded entities with respect to employment and certain excise taxes.

Religious and Family Member FICA and FUTA Exceptions Extended to Disregarded Entities

The IRS issued temporary and proposed regulations that extend the religious and family member FICA and FUTA tax exceptions to disregarded entities.

Providing Fringe Benefits to S Corporation Employees

In an S corporation, employee fringe benefits paid on behalf of a 2% shareholder are subject to special rules.

Tax Issues and the 2010 S Corporation Shareholder Decedent

A tax practitioner working with the estate of an S corporation shareholder who died in 2010 must contend with numerous issues. This article points out some of the issues and discusses some of the choices that can be considered.

IRS Proposes New Treatment of LLC Members, Limited Partners Under Passive Loss Rules

The IRS issued proposed regulations that would redefine “interest in a limited partnership as a limited partner” for purposes of determining material participation under the Sec. 469 passive loss rules.

Final Regs Issued on Debt Satisfied by a Partnership Interest

The IRS issued final regulations on the application of Sec. 108(e)(8) to partners and partnerships.

Current Developments in S Corporations (Part II)

This article provides an annual update of recent IRS rulings, guidance, and other developments concerning S corporations. It discusses S corporation eligibility, elections, termination issues, second class of stock, and trusts owning S corporation stock.

Regs. Extend Religious and Family Member FICA, FUTA Exceptions to Disregarded Entities

Temporary and proposed regulations extend the religious and family member FICA and FUTA tax exceptions to disregarded entities.

Final Regs Clarify Excise, Employment Tax Treatment of Disregarded Entities

The IRS issued final regulations clarifying the treatment of disregarded entities with respect to employment and certain excise taxes.

IRS Proposes Eliminating De Minimis Partner Rule

The IRS issued proposed regulations on October 24 that, if finalized, would remove the de minimis partner rule in Regs. Sec. 1.704-1(b)(2)(iii)(e) (REG-109564-10).

The Targeted Allocations Approach: A Basic Primer

This item discusses a growing trend in the allocation provisions of partnership agreements in which limited partnerships have been adopting a targeted allocation approach through which “tax follows cash.”

QSSTs and ESBTs: No Longer Mutually Exclusive

Under Letter Ruling 201122003, if a current ESBT allows for separate and independent trust shares under the trust document, a trust may be treated as both an ESBT and a QSST. This ruling opens the door for additional planning for gifts of S corporation stock to younger generations.

Sec. 179D and Passthrough Entities

The Sec. 179D deduction available for building designers has unexpected consequences for design firms structured as passthrough entities.

Final Regs. Govern Election to Deduct Business Start-up Expenses

The IRS issued final regulations (T.D. 9542) governing elections by individual taxpayers, corporations, and partnerships to deduct start-up expenses or organizational expenditures.

Current Developments in S Corporations (Part I)

This two-part article discusses in the S corporation area. Part I covers new tax laws, court cases, regulations, revenue procedures, and rulings on various S corporation administrative and operating provisions.

Election to Deduct Business Startup Expenses Gets Final Rules

The IRS issued final regulations governing elections by individual taxpayers, corporations and partnerships to deduct startup expenses or organizational expenditures.

Separately Identifiable Intangible Assets: Tax Opportunities and Traps

Treating self-created customer-based intangibles as assets separate from goodwill can result in more favorable tax treatment for these intangibles. This article examines the rules regarding the separate treatment of self-created customer-based intangibles and the situations in which separate treatment may be beneficial.

S Corporation Shareholder Compensation: How Much Is Enough?

This article looks at recent court decisions regarding S corporation shareholder reasonable compensation that provide helpful guidance on how an adviser can determine what is reasonable compensation.
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