A presidential regulatory freeze had delayed the proposed regulations' publication from early in 2017.
PLLC member-managers are held to not be entitled to a self-employment income exclusion of distributive shares.
The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.
The AICPA leads effort to promote state-level uniformity.
The IRS released a package of proposed provisions that will apply to the recently enacted centralized audit regime that generally assesses and collects tax at the partnership level.
Forming interest charge domestic international sales corporations can save U.S. exporters a great deal of taxes, but many qualifying taxpayers don’t know about them.
The IRS issued rules regarding the time, manner, and form for partnerships to make the election to apply the recently enacted unified partnership audit rules for certain years before Jan. 1, 2018.
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TEFRA and electing large partnership rules are repealed.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.