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.
TEFRA
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.
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.
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.
AICPA recommends flexibility in partnership audits
The IRS should provide a simplified adjustment procedure for partnership audits, the AICPA recommended in a letter to the IRS Chief Counsel’s Office.
Proposed regs. would govern partnership audit adjustments
The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.
IRS issues final rules on election out of centralized partnership audits
IRS final regulations govern electing out of centralized partnership audits.
Partnership audit adjustments addressed in proposed regs.
The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.
Current developments in partners and partnerships
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
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.
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.
