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.
Partnership & LLC Taxation
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.
Final regs. issued on foreign partnership interests
Rules govern withholding on transfers and ECI.
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.
Centralized partnership audit regime changes proposed
The IRS issued rules on two special enforcement matters for purposes of the unified partnership audit rules.
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.
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.
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.
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.
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.
Partnership form being redesigned for 2021
The IRS proposes modifying the partnership form (Form 1065) to help standardize the format of international tax items.
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.
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.
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.
$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.
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.
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.
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).
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.
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.
