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Partnerships Tax Liability Business Taxes

Williams Mullen

Better Late Than Never - The IRS Issues Final Regulations on the Allocation of Recourse Partnership Liabilities After More Than a...

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On November 29, 2024, the United States Internal Revenue Service (the “IRS”) released final regulations (Final Regulations) relating to the allocation of recourse partnership liabilities under section 752 of the Internal...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

Bodman

Michigan Flow-Through Entity Tax Election Deadline Approaching

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Michigan taxpayers with interests in calendar year-end S corporations and partnerships should take note: the deadline to make a new “flow-through” entity tax (“FTE tax”) election for 2024 is approaching, and it occurs prior...more

Latham & Watkins LLP

New IRS Unit Leverages AI to Step Up Partnership Audits; Hundreds of New Inquiries Expected

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The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more

Lowndes

Have a Partnership? March 15th Deadline Offers a Window of Opportunity

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Many senior housing properties are owned by limited liability companies or other entities that are taxed as partnerships for federal income tax purposes. The March 15th deadline for filing federal partnership tax returns is...more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Freeman Law

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with...

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The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has just released Notice 2022-36 which provides an...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

McDermott Will & Schulte

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

Morgan Lewis

IRS Releases Tax Return Amendment Relief for BBA Partnerships

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The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Lowndes

Reminder: Partnership and S Corporation Returns Due Today

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As I previously discussed, the federal tax due date for partnership and corporate tax returns changed a few years ago. ...more

Poyner Spruill LLP

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

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Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Burr & Forman

Don’t Forget to Update Your Operating Agreement for Partnership Audit Rule Changes

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The Bipartisan Budget Act of 2015 enacted sweeping changes to the federal audit regime for entities taxed as partnerships. The new audit rules became effective for tax years beginning on or after January 1, 2018. For tax...more

Butler Snow LLP

Congress Fixes “Grain Glitch” Error in 199A

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On March 23, the Consolidated Appropriations Act (the “Appropriations Act”) was signed into law by President Trump. Included in the Appropriations Act were certain tax law provisions, including technical corrections to the...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Pullman & Comley, LLC

Partnerships and Limited Liability Companies Take Note: Significant Changes in IRS Audit Procedures Take Effect January 1, 2018

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Under pre- 2018 rules, when a partnership (which for this Client Alert will include a limited liability company which is taxed as a partnership) was audited by the IRS, one of the partners acted as the “Tax Matters Partner”...more

Carlton Fields

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

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A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

Bracewell LLP

Can Foreign Partners Now Exit Partnerships Tax Free?

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In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

Orrick, Herrington & Sutcliffe LLP

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Introduces Long-Awaited Proposed Regulations Addressing the Allocation of Partnership Liabilities and Partnership Disguised...

On January 29, 2014, the Internal Revenue Service (the IRS) and the Treasury Department (Treasury) introduced a long-awaited package of proposed regulations (the Proposed Regulations) that would significantly change the rules...more

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