This discussion focuses on the withholding regime under the proposed regulations applicable to non-publicly traded partnerships and highlights a number of compliance and practical implications.
Gains & Losses
Treasury never finalized the bulk of the regulations implementing Sec. 465, so reliance on proposed regulations issued in 1979 is the norm.
This article explains the tax implications of owning and selling an interest in a publicly traded partnership treated as a partnership and the tax reporting and compliance challenges that an investor in a PTP may face.
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.
The IRS concluded that a taxpayer was not permitted to aggregate the S corporations with the partnership for the purpose of applying the at-risk rules of Sec. 465.
This discussion gives a historical perspective of the treatment of the sale of a partnership interest and the changes enacted as part of the TCJA.
The IRS announced that it was withdrawing temporary regulations on the treatment of partnership liabilities for disguised-sale purposes and proposing to reinstate the old rules.
The IRS announced that S corporations are subject to the new extended three-year holding period applicable to carried interests.
Publicly traded partnerships can present challenges for reporting.
The IRS announced that the new three-year holding period for carried interests applies to S corporations as well as partnerships.
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
A CCA memorandum addressed the allocation of partnership losses where certain partners had negative capital account balances.
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.
A preparer’s improper change of status of income from active to passive is costly for taxpayers.
Should the IRS consider recognizing a contributing partner’s economic risk of loss when the regulations are finalized?
Treasury and the IRS issued regulations that generally override nonrecognition treatment for certain contributions of property to partnerships.
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.
Property transfers between a partner and a partnership are considered to be a taxable sale of the property under certain circumstances.
This article discusses the tax treatment of worthless or abandoned stock and partnership interests.
The regulations would create an exception to the general nonrecognition rule for property contributions to a partnership in exchange for a partnership interest.