News & Analysis as of

Proposed Regulation Partnerships Audits

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

Rivkin Radler LLP

Partnership Losses on Related Party Sales – The IRS Provides Some Clarification

Rivkin Radler LLP on

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

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

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

McGuireWoods LLP

Time to Update Your Partnership Agreement: New Rules Address Partnership Representatives for IRS Audits

McGuireWoods LLP on

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

Morrison & Foerster LLP

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

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

Troutman Pepper Locke

Proposed Regulations Re-Released for Centralized Partnership Audit Rules

Troutman Pepper Locke on

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

K&L Gates LLP

The Trump Freeze Leaves New Proposed Regulations on Partnership Audit Rules out in the Cold

K&L Gates LLP on

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

Lowndes

IRS Pulls Proposed Partnership Audit Regulations

Lowndes on

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

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