Regulations quash taxpayers' position that partners can be employees of a disregarded entity owned by the partnership.
TEFRA and electing large partnership rules are repealed.
This tax planning tool can significantly increase the ultimate proceeds realized by the legacy partners upon exiting their investment in an operating partnership.
The new rules would apply to partnership returns filed for tax years beginning after Dec. 31, 2017.
The court will determine the partners' accuracy-related penalties in a partnership proceeding.
Payment for services would be determined by six nonexclusive factors.
The federal highway funding extension bill passed by Congress contains several tax provisions, including changing the due dates for partnership, S corporation, and corporate tax returns, a provision the AICPA has long advocated.
The IRS will apply a six-factor test to determine whether payments to partners are disguised payments for services under proposed regulations issued today.
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).
The IRS issued temporary regulations designed to prevent corporations from avoiding gain on the distribution of appreciated property through the use of partnerships.
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.
The IRS issued proposed regulations that govern the tax treatment of transfers of installment obligations in exchange for equity interests in corporations or partnerships.