Debt arrangement did not give rise to an interest in partnership equity
The Tax Court respects a property developer’s interest deductions despite the lender’s entitlement to a share of net profits.
This site uses cookies to store information on your computer. Some are essential to make our site work; others help us improve the user experience. By using the site, you consent to the placement of these cookies. Read our privacy policy to learn more.
The Tax Court respects a property developer’s interest deductions despite the lender’s entitlement to a share of net profits.
But related income allocations did not have substantial economic effect because the partnership did not properly maintain capital accounts, the Tax Court held.
FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.
Final regulations, issued last week, except certain partnership-related items from the regime and provide alternative rules for their examination by the IRS, as well as provide rules for the calculation of imputed underpayments.
Revised draft instructions for partnership and S corporation Schedules K-2 and K-3 contain significant changes to the requirements to qualify for the domestic filing exception for filing and furnishing the 2022 schedules.
The Ninth Circuit’s holding is ‘in serious tension’ with precedent and misconstrues regulations, the government argues.
Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
If a delinquent return is submitted to and received by an authorized IRS official requesting it, the return need not be sent to an IRS service center to be considered filed, the appellate court stated.
In eight new FAQs on its website, the IRS covers some special issues, including several that it says will be added to the forms’ instructions.
The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.
John Samtoy, CPA, discusses Schedules K-2 and K-3 for passthrough entities and U.S. persons who are partners in foreign partnerships, and how tax professionals can help clients with them.
Comment letters from the AICPA and state CPA societies also offer further recommendations.
The new schedules for returns of passthrough entities with international items have been greeted with antipathy by practitioners. The IRS provided relief Wednesday for eligible entities for tax year 2021.
Guidance includes sample worksheets and instructions for applicable passthrough entities and taxpayers.
A law change and some regulations take effect while an array of provisions expire.
Notice does not affect the status of already recognized organizations.
Forgiveness amounts are excluded from gross income but included in gross receipts for purposes including determining “small business taxpayer” status under Sec. 448(c).
The IRS posted FAQs with sample worksheets and instructions for taxpayers to use when calculating and reporting certain net long-term capital gains from partnership interests held in connection with the performance of services that must be recharacterized as short-term capital gains.
SPONSORED REPORT
This comprehensive report looks at the changes to the child tax credit, earned income tax credit, and child and dependent care credit caused by the expiration of provisions in the American Rescue Plan Act; the ability e-file more returns in the Form 1040 series; automobile mileage deductions; the alternative minimum tax; gift tax exemptions; strategies for accelerating or postponing income and deductions; and retirement and estate planning.