TEFRA

PTE deduction: Timing issues for accrual-method taxpayers

taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.

Notice listing syndicated conservation easement transactions held invalid

Notice identifying syndicated conservation easement transactions as listed transactions is held invalid.

FinCEN provides time estimates for compiling beneficial ownership details

FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.

FinCEN proposes rules about access to beneficial ownership information

Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.

Domestic filing exception requirements modified in draft Scheds. K-2, K-3

Revised draft instructions for partnership and S corporation Schedules K-2 and K-3 contain significant changes to the requirements to qualify for the domestic filing exception for filing and furnishing the 2022 schedules.

Partnership examinations: Imputed underpayment modification

This item discusses how to request modification of an imputed underpayment.

Meaning of ‘filed’ defined for purposes of delinquent partnership returns

Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;

Depreciation recapture in the partnership context

This item discusses how depreciation recapture applies in certain situations involving partnerships.

Tennessee taxation of passthrough entities

An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.

State tax considerations around the sale of a partnership interest

This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.

More Schedule K-2 and K-3 FAQs posted

In eight new FAQs on its website, the IRS covers some special issues, including several that it says will be added to the forms’ instructions.

BBA partnership audits show high no-change rate, TIGTA says

The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.

AICPA again asks IRS to delay K-2/K-3 reporting

Comment letters from the AICPA and state CPA societies also offer further recommendations.

IRS offers further K-2/K-3 relief

The new schedules for returns of passthrough entities with international items have been greeted with antipathy by practitioners. The IRS provided relief Wednesday for eligible entities for tax year 2021.

Complying with new schedules K-2 and K-3

What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.

IRS rules on cancellation of debt of a disregarded entity

Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.

Reporting aspects of Sec. 743(b) adjustments

Partnerships and their partners need to work closely to maintain strong communications to overcome challenges to information sharing and, ultimately, to computational matters and information reporting.

Further guidance issued on tax treatment of PPP loan forgiveness

Forgiveness amounts are excluded from gross income but included in gross receipts for purposes including determining “small business taxpayer” status under Sec. 448(c).

Carried interest reporting FAQs and guidance posted

The IRS posted FAQs with sample worksheets and instructions for taxpayers to use when calculating and reporting certain net long-term capital gains from partnership interests held in connection with the performance of services that must be recharacterized as short-term capital gains.

Guidance issued for LLCs seeking tax-exempt recognition

The IRS clarified the standards that an LLC must satisfy to obtain a determination letter that it is exempt from taxation under Sec. 501(c)(3).
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