The Ninth Circuit’s holding is ‘in serious tension’ with precedent and misconstrues regulations, the government argues.
Partnership & LLC Taxation
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.
The IRS clarified the standards that an LLC must satisfy to obtain a determination letter that it is exempt from taxation under Sec. 501(c)(3).
Errors by partnerships in reporting partners’ tax capital accounts under new rules for 2020 may be excused, the Internal Revenue Service outlined.
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.
Rules govern withholding on transfers and ECI.
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.
The IRS issued rules on two special enforcement matters for purposes of the unified partnership audit rules.
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.