Reporting & Filing Requirements

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.

Top 10 Easy Ways That Trusts Cause Loss of S Corporation Status

This item presents 10 ways that S corporations can lose their S election status, most of them involving trusts.

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.

Ordinary Deduction for Worthless QSub Stock

Restructuring an existing QSub in an attempt to qualify for an ordinary deduction is prohibited and might result in an unfavorable deferral of loss.

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.

Congress Changes Partnership Audit Procedures

The Bipartisan Budget Act of 2015 greatly strengthened the IRS’s ability to examine certain partnerships.

Current Developments in Partners and Partnerships

This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.

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.

IRS Clarifies That a Former QSub Cannot Prorate Post-Termination Items of Income or Loss

IRS addressed whether an S corporation and its wholly owned subsidiary, a QSub, must prorate annual income following a midyear voluntary revocation of subchapter S election.

Making a Trust an Eligible S Corp. Shareholder: QSST and ESBT Elections

This item describes eligible shareholder trusts and the elections they must make.

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.

QSST Not Necessarily Required to Pay All Income to Beneficiary

If a qualified subchapter S trust (QSST) owns both S corporation stock and other assets, determining whether the income from the other assets must be distributed to the beneficiary depends on the terms of the trust document.

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.

QSub Status Is Not Property of Bankruptcy Estate

An S corporation’s revocation of its S corporation status, which caused its QSub subsidiary to lose its status as a QSub, was not a post-bankruptcy-petition transfer of property of the QSub’s bankruptcy estate.

QSub Election Does Not Increase Shareholder Stock Basis

The Tax Court held that shareholders of an S corporation improperly increased the adjusted basis of their S corporation stock when the S corporation made a QSub election for its wholly owned C corporation subsidiary.
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