Reporting & Filing Requirements

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.

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.

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.
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