Partnership and LLC Taxation

Dissolution of an LLC

Procedures for concluding the affairs of the LLC should be included in the operating agreement.

Practitioner’s incorrect change to passive status costly

A preparer’s improper change of status of income from active to passive is costly for taxpayers.

IRS reissues centralized partnership audit rules

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

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.

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.

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.

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.

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.

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.
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