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.
Gains & Losses
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.
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.
A CCA memorandum addressed the allocation of partnership losses where certain partners had negative capital account balances.
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
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.
IRS Chief Counsel Advice interpreted whether Sec. 752 should be used to determine whether a partnership’s debt is recourse or nonrecourse for purposes of COD income rules.
A partnership distribution may consist of cash, property, or both. In addition, any reduction of a partner’s share of partnership liabilities is treated as an actual distribution of cash.
The IRS intends to issue regulations under Sec. 721(c) to ensure that a U.S. person recognizes gain either immediately or periodically when it transfers certain property to a partnership that has foreign partners related to the transferor.