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New Proposed Regulations Turn Off the Centralized Partnership Audit Rules in Certain Cases and Provide Guidance on QSub Partners

On Nov. 20, 2020, the IRS and Treasury Department released proposed regulations on the centralized partnership audit rules enacted as part of the Bipartisan Budget Act of 2015 (the BBA Rules). The proposed regulations allow...more

12/7/2020  /  Audits , Bipartisan Budget , IRS , Partnerships , QSub

IRS Employee Retention Tax Credit Guidance for Acquisitions of PPP Borrowers

The IRS recently updated its Employee Retention Tax Credit (ERTC) FAQs, providing additional guidance regarding the effect on ERTC eligibility of mergers and acquisitions involving Paycheck Protection Program (PPP) loan...more

IRS Clarifies Availability of Employee Retention Tax Credit

The IRS has issued extensive FAQs addressing application of the employee retention tax credit (ERTC), including employer eligibility and determination of qualified wages. Enacted as part of the Coronavirus Aid, Relief, and...more

No Deduction Allowed for Expenses Resulting in PPP Forgiveness

Ending weeks of speculation and debate, the IRS has issued guidance confirming that no deduction is allowed for an otherwise deductible expense if the payment of the expense results in forgiveness of a Paycheck Protection...more

IRS Offers Advance Funding of Employee Retention Tax Credit

Businesses searching for immediate cash should not overlook the fully refundable employee retention tax credit (ERTC), which permits employers to reduce their deposits of federal employment taxes and even request advances...more

Administrative Relief: IRS Will Allow Partnerships To File Amended Returns and Real Property Businesses To Undo Interest Expense...

As promised, the IRS has begun to issue guidance assisting taxpayers in applying the retroactive aspects of the CARES Act. To address the disconnect between certain partnerships’ ability to file amended returns and the CARES...more

Final Pass-Through Regulations Issued Just in Time for Filing Season

As discussed in our prior alert, the proposed Section 199A regulations provided welcome guidance regarding the application of the pass-through deduction across related entities but left many questions unanswered. ...more

IRS Provides Real Estate Rental Safe Harbor to Qualify for Pass-Through Deduction

When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more

Opportunities and Limitations: Proposed Pass-Through Deduction Regulations Provide Clarity

Since new Section 199A was enacted late last year as part of the Tax Cuts and Jobs Act (the TCJA, discussed in Congressional Conferees Approve Long-Awaited Tax Reform), business owners and tax professionals alike have been...more

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