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.
TEFRA
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.
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.
