Partnership & LLC taxation

TOPICS

January 20, 2021

Partner capital account reporting gets transition penalty relief

Errors by partnerships in reporting partners’ tax capital accounts under new rules for 2020 may be excused, the Internal Revenue Service outlined.

January 8, 2021

Carried interests regulations are finalized

The IRS finalized proposed regulations on certain carried interests to account for changes made by the Tax Cuts and Jobs Act (TCJA). The TCJA extended from one year to three years the holding period for making carried interests eligible for capital gain treatment.

January 1, 2021

Final regs. issued on foreign partnership interests

Rules govern withholding on transfers and ECI.

December 1, 2020

Business tax quick guide — tax year 2020

Download or print this quick guide for use during tax season, and look for our quick guide for individual taxpayers in the January 2021 issue.

November 20, 2020

Centralized partnership audit regime changes proposed

The IRS issued rules on two special enforcement matters for purposes of the unified partnership audit rules.

November 10, 2020

Partnerships and S corps. can deduct state and local taxes

The IRS said it would issue proposed regulations allowing S corporations and partnerships to deduct “specified income tax payments” paid to state and local governments above the line and not as passthrough items for partners and shareholders.

October 22, 2020

Draft instructions for partnership capital account reporting released

The IRS released draft instructions for Form 1065, U.S. Return of Partnership Income, to calculate partner capital accounts using the tax-basis method.

October 8, 2020

Rules govern withholding on transfers of partnership interests and ECI

The IRS finalized proposed regulations on withholding from transfers of partnership interests to foreign persons and the definition of effectively connected income for those purposes.

October 1, 2020

Settlement agreement’s capital gain allocation withstands challenge by IRS

The Tax Court finds a payment was for repudiated joint venture interests, not future income.

August 3, 2020

Proposed rules govern carried interests

The Irs issued proposed regulations under Sec. 1061, enacted by the law known as the Tax Cuts and Jobs Act, which requires owners of certain partnership interests to hold them for three years to be eligible for capital gain treatment.

July 15, 2020

Partnership form being redesigned for 2021

The IRS proposes modifying the partnership form (Form 1065) to help standardize the format of international tax items.

April 8, 2020

Partnerships can file amended returns to get CARES Act benefits

To allow those partnerships to take advantage of the beneficial tax provisions in the Coronavirus Aid, Relief, and Economic Security Act, the IRS is allowing partnerships to file amended returns for 2018 or 2019.

March 9, 2020

Getting states on board: A model for partnership tax audits

The rules have changed for IRS examinations and adjustments of partnership returns at the federal level, but are the states following suit? We’ll find out how model legislation issued by the Multistate Tax Commission, developed in collaboration with the AICPA and other stakeholders, is being adopted across the U.S.

March 1, 2020

$8.7 million partnership income adjustment by IRS disallowed

Family mobile home business’s promissory notes were not includible in income, the Tax Court holds.

March 1, 2020

Why states need to enact MTC model statute in 2020

Campaign seeks to create a uniform state-by-state regime that aligns with changes to federal partnership audits.

February 19, 2020

AICPA requests clarity on Sec. 465 reporting relief

The AICPA has asked Treasury and the IRS to clarify that reporting relief on certain reporting under Sec. 465 will also apply to S corporations.

December 23, 2019

Humpty Dumpty meets the tax code

Annette Nellen, Esq., CPA, CGMA, walks us through four recent decisions by the U.S. Tax Court to show how the precise application of a word or phrase can make a world of difference.

December 10, 2019

Partnership capital reporting requirements postponed until 2020

The IRS is postponing the requirement to report partners’ shares of partnership capital on the tax-basis method for 2019 (for partnership tax years beginning in calendar 2019) until 2020 (for partnership tax years that begin on or after Jan. 1, 2020).

December 1, 2019

Father’s treatment of partnership interest expense does not bind son

The son, who inherited and received as gifts the interests in real estate partnerships, could treat nonrecourse debt as acquisition indebtedness, the Tax Court holds.

July 29, 2019

IRS permits certain partnerships to file superseding partnership returns

The IRS is permitting certain partnerships that timely filed their tax returns for the 2018 tax year an extension of time to file superseding returns and Schedules K-1 for their partners.