TEFRA

Navigating the new Schedules K-2 and K-3

Schedule K-2 will report the partnership/S corporation–level activity attached to a flowthrough return, while Schedule K-3 will be provided to each partner or shareholder and report its proportionate amount for each item.

The Sec. 1061 capital interest exception and its impact on hedge funds

A hedge fund manager may be required to maintain separate tracking of a single partnership interest into several buckets to avoid the negative tax consequences of the short-term capital gain treatment of assets held from one to three years under Sec. 1061 for certain partnerships on the economic return of their invested capital.

Sec. 1446(f) regulations: The rules and unanswered questions

This article addresses certain aspects of the withholding rules of the final Sec. 1446(f) regulations, options to eliminate or reduce Sec. 1446(f) withholding, and some outstanding issues.

Current developments in partners and partnerships

This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.

Partner capital account reporting gets transition penalty relief

Errors by partnerships in reporting partners’ tax capital accounts under new rules for 2020 may be excused, the IRS outlined.

Draft instructions for reporting partnership capital accounts are issued

The IRS released draft instructions for Form 1065 to calculate partner capital accounts using the tax-basis method.

Draft instructions for partnership capital account reporting released

The IRS released draft instructions for Form 1065, U.S. Return of Partnership Income, to calculate partner capital accounts using the tax-basis method.

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.

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.
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