Partnership Taxation
Tax Court affirmed the IRS’s decision to recharacterize loss of a partnership disposition from ordinary to capital when the taxpayers failed to provide evidence of abandonment.
To ease the regulatory burden on partnerships, the IRS announced that it is eliminating the requirement that partnership elections under Sec. 754 be signed by a partner.
A preparer’s improper change of status of income from active to passive is costly for taxpayers.
Procedures for concluding the affairs of the LLC should be included in the operating agreement.
The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
A bonus payment to a hedge fund manager was payment for services outside her capacity as a partner.
Partnerships must reevaluate their current fiscal year when a partner dies, since the estate may have a different year end than the individual partner.
Should the IRS consider recognizing a contributing
partner’s economic risk of loss when the regulations are finalized?
Where there are no adjustments to partnership items, a taxpayer could not hide behind the Sec. 6230(a)(2)(A)(i) exclusion.
The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
This article examines the PATH act provisions and other developments favorable for taxpayers.
The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
This item explains how the final regulations differ from the proposed regulations.
A responsible person may be subject to the TFRP if it can be shown he or she willfully failed to pay the trust fund taxes due.
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
Sec. 743(b) adjustments are complex, and multitier partnership structures only exacerbate that complexity.
The Tax Court held that a taxpayer had not elected to group two activities together under the passive
activity loss rules simply by treating both activities as nonpassive.
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.
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
This column focuses on what happens when a partnership’s business activities cease.
