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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
Few individual owners of a closely held business would be surprised if you explained to them that the IRS and the Federal courts generally will subject many transactions between certain “related” persons to heightened...more
Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more
Last week, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations concerning the designation and authority of a partnership representative under the centralized partnership audit regime...more
The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more
New partnership audit rules enacted into law on November 2, 2015 (the “Centralized Partnership Audit Rules”) (previously discussed in our QuickStudy: Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and...more
A White House freeze on recently issued regulations has left proposed regulations on the new Centralized Partnership Audit Regime out in the cold. On January 20, 2017, a memorandum from Assistant to the President and Chief...more
As I previously discussed, the IRS released last week long awaited regulatory guidance addressing the new partnership audit rules. The status of these proposed regulations is unclear, though, as the IRS officially withdrew...more