News & Analysis as of

Internal Revenue Service K-1 Partnerships

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Latham & Watkins LLP

IRS Launches New Large Partnership Audits, Relying on AI and Increased Funding

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The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more

McGlinchey Stafford

CARES Act Updates Tax Act’s Depreciation Period – Act Fast

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Before the enactment of the 2017 Tax Cuts and Jobs Act (TCJA), qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property had a 15-year recovery period for depreciation...more

Proskauer - Tax Talks

Section 1446(f) Proposed Regulations: Key Guidance on Partnership Interest Transfers by Non-U.S. Persons

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On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more

Mitchell, Williams, Selig, Gates & Woodyard,...

What Practitioners Need to Know about the New Partnership Audit Rules

As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more

Troutman Pepper Locke

Tax Update, Volume 2017, Issue 2

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THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

Troutman Pepper Locke

Practical Partnership Tips: Electronic K-1s and Addressing New Partnership Audit Rules: Tax Update Volume 2017, Issue 2

Troutman Pepper Locke on

Partnerships and limited liability companies should begin thinking about addressing the issues presented by the new partnership law in their agreements, even if further changes will be necessary once regulations are issued....more

Clark Hill PLC

IRS Clarification Causes Many Partnerships to Change Compensation Reporting for Partners

Clark Hill PLC on

A federal tax issue frequently arises when key employees of an operating business are given the opportunity to become equity holders. Despite the well-established rule that partners of a partnership are not permitted to be...more

Foster Garvey PC

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

Foster Garvey PC on

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

Troutman Pepper Locke

Be Careful in Granting Profits Interests to Your Key Employees; New IRS Regulations Suggest the IRS is Keen on Form K-1 Filing

Troutman Pepper Locke on

On May 5, 2016, the Department of Treasury and the Internal Revenue Service published final and temporary regulations amending Treasury Regulations §301.7701-2 under Section 7701 of the Internal Revenue Code of 1986, as...more

K&L Gates LLP

IRS Sets Short Fuse for Comments, Guidance on New Partnership Audit Rules

K&L Gates LLP on

As if it wasn’t going to be busy already, the Internal Revenue Service (“IRS”) has set Tax Day, April 15, 2016, as the due date for comments on significant new partnership audit rules. This new law, which was enacted as part...more

Latham & Watkins LLP

New Tax Audit Regime Constitutes a Sea Change for Partnerships

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Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect. The Bipartisan Budget Act of 2015 (the Act), which President Obama...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Stinson LLP

Sweeping Change to Partnership Tax Audit Procedures

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A major change to partnership audits was signed into place by President Barack Obama on November 2nd following the passage of the Bipartisan Budget Act of 2015 by Congress on October 30th. Previously, partnerships with more...more

Bond Schoeneck & King PLLC

New Tax Provisions Affecting Filing Deadlines For Partnerships, Corporations and Trusts (8/15)

On July 31, 2015, President Obama signed into law P.L. 114-41, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015." Although this new law was primarily designed as a 3-month stopgap extension...more

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