Partnership & LLC taxation

TOPICS

September 1, 2025

Tax Court denies $23 million façade easement deduction

The Tax Court denied a limited liability company’s (LLC’s) claimed charitable conservation contribution deduction under Sec. 170(h) for its donation of a façade easement because the LLC failed to establish that the building was a “certified historic structure” under Sec. 170(h)(4)(C). The court also rejected the LLC’s argument that the

August 18, 2025

Prop. regs. would modify reporting obligations for Form 8308, Part IV

The IRS issued proposed regulations that would modify partnerships’ reporting obligations for Part IV of Form 8308 with respect to sales or exchanges of certain interests in partnerships owning inventory or unrealized receivables.

August 4, 2025

IRS includes several AICPA recommendations in corporate AMT interim guidance

In a notice issued Tuesday, the IRS said it intends to partially withdraw proposed regulations and issue revised proposed regulations.

August 1, 2025

LLC lacks reasonable cause for information-reporting failures

An auto dealership failed to prove that its software operated incorrectly or that it had adequate controls to identify noncompliance, the Tax Court held.

July 1, 2025

Tax Court denies limited-partner exception to self-employment tax

The court again applies a functional-analysis test, as it had in Renkemeyer and Soroban.

June 25, 2025

AICPA proposes changes to Senate bill that would help most US businesses

Passthrough entities would lose ground compared with corporations under tax language in the Senate Finance Committee bill, the AICPA said in a letter to legislative finance leaders.

June 16, 2025

AICPA makes Priority Guidance Plan recommendations to IRS

In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.

May 18, 2025

Reconciliation bill clears committee on second try

Sunday revote came after Republican fiscal hawks initially joined Democrats to sink the bill, which includes tax provisions approved by the House Ways and Means Committee last week.

May 18, 2025

Ways and Means approves proposed TCJA extensions and tax changes

The bill would make key portions of the TCJA permanent and create a new “senior bonus” deduction, among its many provisions. An AICPA statement said it is “deeply troubled” by the plan to curtail use of passthroughs to avoid SALT cap. The bill now heads to the House Budget Committee.

December 13, 2024

IRS grants partnerships additional time to furnish complete Forms 8308

The IRS is providing relief from penalties imposed solely for failure to furnish Part IV of Form 8308 for partnerships by Jan. 31, 2025, if a partnership meets certain requirements.

December 2, 2024

Regs. address partnership recourse liabilities, related-party rules

The IRS issued regulations that finalize proposed regulations issued in 2013. The guidance is focused on when and to what extent a partner is treated as bearing the economic risk of loss and the special rules applying to a partner related to another partner.

October 1, 2024