The Bipartisan Budget Act of 2015 fundamentally changes the rules and procedures governing IRS audits of partnerships for taxable years beginning on or after January 1, 2018. These new rules are contained in new Sections...more
The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more
Late last month, the Treasury Department issued proposed regulations that address partnership liabilities (section 752) and disguised sales of property (Internal Revenue Code section 707). If enacted, the section 752...more