Final rules govern election out of centralized partnership audits
The IRS finalized the rules for determining whether partnerships are eligible to elect out of the centralized audit procedures enacted in 2015, which apply to partnerships this year.
Reporting & Filing Requirements
Developing a uniform state approach to the new federal partnership audit regime
This column, the first of two parts, discusses issues states must consider and steps some have taken to align partnership audit rules with new federal rules.
Liability for payment of employment taxes when using a PEO
Chief Counsel Advice was issued regarding who is ultimately liable for payment of employment taxes when using a professional employment organization.
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.
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.
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.
S corporation owner-employees: Who controls income?
Clients who wish to have income from services be treated as income of their corporations should have revise independent contractor agreements so that payments are made to their corporations.
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.
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.
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.
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.
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.
IRS Issues Temporary Regulations on Early Elections 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.
Partnership Audit Rules for the Next Decade
This article analyzes new rules regarding the audit procedures for partnerships and describes important elections partnerships may make.
IRS Asks for Comments Before Issuing Partnership Audit Rules
The IRS requested comments on several issues to assist it in issuing regulations to implement the new rules for partnership audits that were passed by Congress last year to replace the long-standing TEFRA audit regime.
Current Developments in Partners and Partnerships
This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.
Congress Changes Partnership Audit Procedures
The Bipartisan Budget Act of 2015 greatly strengthened the IRS’s ability to examine certain partnerships.
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.
