Sec. 1446(f) regulations: The rules and unanswered questions
This article addresses certain aspects of the withholding rules of the final Sec. 1446(f) regulations, options to eliminate or reduce Sec. 1446(f) withholding, and some outstanding issues.
Reporting & Filing Requirements
Current developments in partners and partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
Partner capital account reporting gets transition penalty relief
Errors by partnerships in reporting partners’ tax capital accounts under new rules for 2020 may be excused, the IRS outlined.
Draft instructions for reporting partnership capital accounts are issued
The IRS released draft instructions for Form 1065 to calculate partner capital accounts using the tax-basis method.
Draft instructions for partnership capital account reporting released
The IRS released draft instructions for Form 1065, U.S. Return of Partnership Income, to calculate partner capital accounts using the tax-basis method.
Current developments in partners and partnerships
This article discusses developments in the taxation of partnerships and partners, debt and income allocations, distributions, and basis adjustments.
Risks and opportunities for third-party partnership representatives
The BBA rules that allow a third party to act on behalf of the partnership, as well as the change in IRS adjustments being assessed at the partnership level, bring significant new challenges for tax practitioners.
IRS permits certain partnerships to file superseding partnership returns
The IRS is permitting certain partnerships that timely filed their tax returns for the 2018 tax year an extension of time to file superseding returns and Schedules K-1 for their partners.
BBA audit regime affects buyers and sellers of partnership interests
This item provides a brief overview of the BBA audit regime and discusses some of the practical considerations that partners may want to keep in mind when buying or selling partnership interests.
IRS finalizes centralized partnership audit rules
The IRS issued final regulations on the centralized partnership audit regime, which generally assesses tax at the partnership level.
IRS finalizes centralized partnership audit regulations
The IRS issued final regulations on the centralized partnership audit regime, which generally assesses tax at the partnership level.
Current developments in partners and partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships and discusses developments in partnership formation, debt and income allocations, distributions, and basis adjustments.
Issues and considerations in appointing a partnership representative
This item discusses issues partnerships and their advisers should consider when designating a PR or DI, accounting for the potential for conflicts of interest, whether and to what extent limitations can be placed on the PR or DI, and how these roles differ dramatically from that of the TMP.
Using R&D credits to reduce payroll taxes: An overlooked opportunity for startups
This article discusses who qualifies to take the credit, how to make the election, the calculation and allocation of the credit, and how to report it.
Rules determine who can be a partnership representative under new audit regime
The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.
S corporation shareholder cannot take FICA tip credit
An S corporation shareholder cannot unilaterally change an S corporation’s tax election in order to claim FICA tip credits.
Final regs. govern who can be a partnership representative
The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.
IRS issues final regs. on electing out of centralized partnership audit regime
The regulations’ definition of an ‘eligible partner’ is key to determining whether a partnership can elect out of the centralized partnership audit regime.
AICPA issues TQA on accounting for payments under the centralized partnership audit regime
The technical question and answer helps financial statement preparers account for the amount a partnership pays the IRS for previous underpayments of tax, interest, and penalties.
Appropriations act tax provisions include IRS funding and audit rules
The $1.3 trillion spending bill passed by Congress includes IRS funding and tax-related technical corrections, including changes to the centralized partnership audit regime.
