News & Analysis as of

Internal Revenue Service S-Corporation 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.  
Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

Allen Barron, Inc.

Important IRS and California Tax-Related Deadlines

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Don't stick your head in the sand and miss important business or personal tax deadlines...more

Williams Mullen

[Event] 2025 Winter Tax Forum - February 6th, Richmond, VA

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Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Allen Barron, Inc.

You Sign Every Tax Return Under The Penalties of Perjury

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Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more

Williams Mullen

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

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On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more

Allen Barron, Inc.

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

Allen Barron, Inc. on

What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

Eversheds Sutherland (US) LLP

Treasury and IRS release final regulations on elective payment election under CHIPS Act Section 48D

On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more

Buckingham, Doolittle & Burroughs, LLC

Gifts of Private Company Interests to Charity Prior to Sale

A planning technique that is known to most tax professionals is for an owner of a private company to gift an interest therein to charity prior to a sale. This technique is only of interest to taxpayers who are charitably...more

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

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As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

PilieroMazza PLLC

Focus on S Corporations, Part 1:  Choosing the Right Entity to Meet Your Small Business Goals

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Most business owners understand the need to create an entity to operate their business. However, beyond general knowledge, many owners are unsure of when is the right time to create an entity and which type of entity makes...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

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Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

Allen Barron, Inc.

It’s Time to Start Making Estimated Tax Payments Again California

Allen Barron, Inc. on

The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Levenfeld Pearlstein, LLC

Are Partner Retirement or Withdrawal Provisions in Governing Documents Subject to Section 409A of the Internal Revenue Code?

As part of our ongoing series on tax issues for accounting firms, this article provides information on retirement or deferred compensation arrangements, the related rules of Section 409A of the Internal Revenue Code, and how...more

Paul Hastings LLP

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

BCLP

The Transferability of Tax Credits: the Creation of Secondary Market Under the Inflation Reduction Act

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The Inflation Reduction Act of 2022 (the “IRA”) represents the largest investment in clean energy and climate change in the history of the United States, with over $370 billion of funding to provide tax credits for clean...more

Rivkin Radler LLP

The Closely Held Business and The Tax Gap

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Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more

Harris Beach Murtha PLLC

IRS Issued Simplified Procedures to Resolve Common S Corporation and QSub Errors

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Failure to meet and maintain the requirements to be treated as an S corporation for federal income tax purposes can result in the loss of S corporation status and the resulting loss of pass-through entity tax treatment. ...more

Foster Garvey PC

A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a...

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More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

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Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Butler Snow LLP

IRS Provides Much Needed Transition Relief for New Schedules K-2 and K-3

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February 18, 2022 On February 16, 2022, the IRS issued a news release along with a set of “Frequently Asked Questions” on new Schedules K-2 and K-3, which must be filed with IRS Forms 1065, 1120-S and 8865. This guidance was...more

Rivkin Radler LLP

Deferring the Tax Hit on a Grant Equity to an Employee – Are You Prepared to Enforce the Forfeiture Provision?

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“Would I ever leave this company? Look, I’m all about loyalty. In fact, I feel like part of what I’m being paid for here is my loyalty. But if there were somewhere else that valued loyalty more highly, I’m going wherever they...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

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