Partnership & LLC taxation

TOPICS

July 1, 2026

District court upholds final microcaptive reporting regulations

The IRS followed a “reasonably discerned path” in setting forth factors triggering designation of a microcaptive insurance arrangement as a listed transaction or transaction of interest, the court found.

May 1, 2026

Fifth Circuit reverses Tax Court on ‘limited partner’ definition

The Fifth Circuit, overruling the Tax Court, held that for purposes of Sec. 1402(a)(13), “limited partner” means a partner in a limited partnership that has limited liability.

March 25, 2026

IRS watchdog cites resource limits, duplication in partnership audits

The Treasury Inspector General for Tax Administration assessed a soft-letter initiative and the IRS’s examinations of 82 major U.S. partnerships.

December 23, 2025

IRS updates FAQs on business interest limitation, premium tax credit

The updates reflect changes made in H.R. 1, P.L. 119–21, commonly known as the One Big Beautiful Bill Act.

December 8, 2025

PTEs need more notice of changes, more time to respond, AICPA says

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations.

December 1, 2025

Tax Court denies bad-debt deduction

Advances made by a taxpayer in its business of managing an arena were not bona fide debt, and the taxpayer was not entitled to a bad-debt deduction when the advances became worthless.

September 25, 2025

Professional liability risks related to Form 1065, CPA firm acquisitions

An author of the JofA’s Professional Liability Spotlight column explains the risks associated with Form 1065 and those related to CPA firm acquisitions. She also shares why a strong employee onboarding process can have risk-management advantages. Listen to the podcast episode or read the Q&A.

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

Partnership made a valid election into the BBA procedures

The IRS could not require that the taxpayer prove, as opposed to represent, that it had enough assets to pay any imputed underpayment, based on the regulation’s plain text.

June 24, 2024

Final regs. issued on conservation easement deduction disallowance

The IRS on Monday issued final regulations providing guidance on the new rule that disallows charitable contribution deductions for certain conservation easement contributions by partnerships and other passthrough entities.