Partnership & LLC taxation

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July 22, 2015

Proposed rules define disguised payments for services in partnerships

The IRS will apply a six-factor test to determine whether payments to partners are disguised payments for services under proposed regulations issued today.

July 1, 2015

Court rejects ‘in-substance’ small-partnership argument

A partnership with a passthrough partner owning a 0.02% partnership interest is ineligible for the small partnership exception under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA).

June 11, 2015

IRS: Corporations cannot circumvent gain on appreciated property using partnerships

The IRS issued temporary regulations designed to prevent corporations from avoiding gain on the distribution of appreciated property through the use of partnerships.

April 13, 2015

IRS disagrees with Tax Court on partners’ COD exclusion

The IRS will not acquiesce to Tax Court decisions allowing general partners who guaranteed the debt of their partnership and were not in bankruptcy in their individual capacity to exclude from gross income cancellation-of-debt (COD) income arising from a Title 11 bankruptcy proceeding of the partnership.

December 23, 2014

Transfers of installment obligations would trigger gain or loss under proposed rules

The IRS issued proposed regulations that govern the tax treatment of transfers of installment obligations in exchange for equity interests in corporations or partnerships.