TEFRA

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 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.

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.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, debt and income allocations, distributions, passive activity losses, and basis adjustments during the period November 1, 2009–October 31, 2010.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, debt and income allocations, distributions, passive activity losses, and basis adjustments.

Partner Allowed to Make Different Elections for Different Partnership Interests

The Tax Court held that taxpayers owning multiple interests in the same partnership were entitled to make different elections under Sec. 6223 for each interest.
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