Government seeks rehearing in Seaview partnership return filing case
The Ninth Circuit’s holding is ‘in serious tension’ with precedent and misconstrues regulations, the government argues.
Partnership & LLC Taxation
Regulations streamline partnership basis elections
Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
IRS agent’s receipt of a copy of an LLC’s return constitutes its filing, Ninth Circuit holds
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.
More Schedule K-2 and K-3 FAQs posted
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.
BBA partnership audits show high no-change rate, TIGTA says
The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.
Grappling with Schedules K-2 and K-3
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.
AICPA again asks IRS to delay K-2/K-3 reporting
Comment letters from the AICPA and state CPA societies also offer further recommendations.
IRS offers further K-2/K-3 relief
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.
Carried interest reporting FAQs posted
Guidance includes sample worksheets and instructions for applicable passthrough entities and taxpayers.
What’s new for 2022 in federal taxes
A law change and some regulations take effect while an array of provisions expire.
How LLCs may obtain tax-exempt recognition
Notice does not affect the status of already recognized organizations.
Further guidance issued on tax treatment of PPP loan forgiveness
Forgiveness amounts are excluded from gross income but included in gross receipts for purposes including determining “small business taxpayer” status under Sec. 448(c).
Carried interest reporting FAQs and guidance posted
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.
Guidance issued for LLCs seeking tax-exempt recognition
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).
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.
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.
