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.
Reporting & Filing Requirements
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.
Special Care Needed in Dealing With Statute-of-Limitation Issues for TEFRA Partnerships
Audits of flowthrough entities such as partnerships cause administrative complexity for the IRS and taxpayers because the audit sometimes drags on longer than the statute-of-limitation period for the IRS to make an adjustment.
Revisiting the Vainisi Decision: Why S Corporation Banks Are Not Completely in the Clear
While the Seventh Circuit's decision in Vainisi was favorable for S corporation banks investing in tax-exempt obligations, those banks nonetheless must pay close attention to the specific type of tax-exempt obligations they purchase if they expect to reap the benefits of that decision.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments
Rough Sailing for TEFRA Partnerships
Several recent cases illustrate the need for taxpayers to be extremely careful when involved in a Taxpayer Equity and Fiscal Responsibility Act audit.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving 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.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, debt and income allocations, distributions, passive activity losses, and basis adjustments during the period November 1, 2009–October 31, 2010.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, debt and income allocations, distributions, passive activity losses, and basis adjustments.
Partner Allowed to Make Different Elections for Different Partnership Interests
The Tax Court held that taxpayers owning multiple interests in the same partnership were entitled to make different elections under Sec. 6223 for each interest.
QSubs Recognized as Separate Entities for Employment and Excise Taxes
Editor: Kevin F. Reilly, J.D., CPA The IRS has issued final regulations that treat qualified subchapter S subsidiaries (QSubs) and other disregarded entities (DEs) as separate entities for federal employment tax and certain excise tax purposes (TD 9356). Although the regulations are effective as of August 16, 2007, the employment
