Partnership and LLC Taxation

Who Is a Limited Partner? The IRS Issues Sec. 469 Prop. Regs.

Despite its importance in assessing an individual’s tax liability, the determination of whether a person is a “limited partner” for federal income tax purposes is often uncertain.

Multistate Partnerships: To Withhold, or Not to Withhold?

The varying rules for withholding can create a compliance nightmare for multistate partnerships with a large number of partners.

The Research Credit and Deduction for Passthrough Entities

Passthrough entities may be overlooking the research tax credit because they are not aware that they are engaged in eligible activities, do not think their activities are qualified, or do not believe they can meet the various requirements.

Final Partnership Debt-for-Equity Regulations

The IRS issued final regulations that provide guidance on the recognition of discharge of indebtedness income in partnership debt-for-equity transfers.

Reporting Dilemma: Personal Use of Rental Properties

Properly apportioning real estate expenses between personal and rental use presents several challenges.

Electronic Schedules K-1

The IRS issued rules partnerships must follow if they want to supply Schedules K-1 electronically.

Application of the Tax Basis and At-Risk Loss Limitations to Partners

Individual partners who have been allocated a distributive share of loss must satisfy three separate loss limitations before the loss can be used.

Family Investment Partnerships: All the Perks

Family investment partnerships are frequently used to manage and control multigenerational family wealth and may result in significant economic and tax benefits.

Banks Are Lenders to Partnership, Not Partners

The Second Circuit held that two banks were lenders to a partnership, not partners in the partnership under Sec. 704(e)(1).

Partnerships Can Issue Schedules K-1 Electronically

The IRS issued rules partnerships must follow if they want to supply Schedules K-1 electronically.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships.

Invalid Sec. 754 Elections: Some Observations

This item discusses the requirements for a valid Sec. 754 election and then highlights some of the reasons for those late or missed elections.

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.

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.

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.
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