The Bipartisan Budget Act streamlined the partnership audit and adjustment processes, but uncertainties remain.
While the deposits can limit interest due on imputed underpayments under the centralized audit regime of the Bipartisan Budget Act of 2015, ambiguities remain, including for push-out elections.
Partnerships’ administrative adjustment requests filed under the Bipartisan Budget Act rules can affect partners in disparate ways, including where adjustments flow through a tiered structure.
Partnerships do well to consider available elections and the power that partnership representatives wield under the audit procedures of the Bipartisan Budget Act of 2015.
The newly expanded form can help transferors of partnership interests meet reporting requirements involving Sec. 751(a) “hot assets” gain or loss, collectibles gain, and unrecaptured Sec. 1250 gain.
In a compliance campaign and litigation, the IRS challenges partners’ claims of the Sec. 11402(a)(13) exception from Self-Employed Contributions Act employment tax liability.
This annual update reviews court rulings and guidance on issues including debt and income allocations, distributions, and basis adjustments.
In Salacoa Stone Quarry, LLC, the Tax Court held that penalties for misstatement of a charitable conservation easement’s value were properly approved by an IRS supervisor, despite a discrepancy in dates on the penalty approval documents.
Clients should start developing procedures and policies to comply with the new reporting requirement and begin to gather the data that will be necessary.
Faxing a return copy to an IRS agent or mailing it to an IRS attorney is not ‘filing’ the return.
taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.
Notice identifying syndicated conservation easement transactions as listed transactions is held invalid.
FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
Revised draft instructions for partnership and S corporation Schedules K-2 and K-3 contain significant changes to the requirements to qualify for the domestic filing exception for filing and furnishing the 2022 schedules.
This item discusses how to request modification of an imputed underpayment.
Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;
This item discusses how depreciation recapture applies in certain situations involving partnerships.
An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.
This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.