Partnership Taxation

Disguised-sale partnership regs. withdrawn

The IRS announced that it was withdrawing temporary regulations on the treatment of partnership liabilities for disguised-sale purposes and proposing to reinstate the old rules.

IRS pursuing self-employment taxes from LLC members

IRS court victories asserting that LLC members should pay self-employment taxes on distributive shares of LLC income should give practitioners pause before claiming this income is exempt from those taxes.

Centralized partnership audit rules proposed

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.

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