Final Regs Allow Certain Co-Owned Elective Pay Entities to Opt Out of Partnership Treatment
The IRS finalized regs providing guidance on how clean energy projects with multiple owners can elect to not be treated …
IRS to Issue Proposed Regs Addressing the Pillar Two GloBE Model Rules
The IRS has announced that it will issue proposed regs addressing how certain Code provisions, including the foreign tax credit …
IRS Releases Final Stock Ownership Determination Regs
The IRS has issued final regs regarding the treatment of domestic partnerships for purposes of determining amounts included in the …
TC: Partner Taxed on Distributive Share, Whether or Constructively Received
The Tax Court has held that a partner was liable for tax on her distributive share of income from the …
2018, 2019 Partnership Forms 1065S may be Amended to Reflect CARES Act
In a Revenue Procedure, IRS has allowed partnerships that are subject to the Bipartisan Budget Act of 2015 (BBA)’s centralized …
Draft 2019 Forms 1065, 1120-S, and Schedules K-1 Released
The IRS has released drafts of the 2019 Form 1065 (U.S. Return of Partnership Income), its Schedule K-1 (Partner’s Share …
New Draft Form Instructions Released for Simplified QBI Computation
The IRS has released draft instructions to the draft Form 8995, Qualified Business Income Deduction Simplified Computation. The Tax Cuts …
Draft of new partnership audit liability form and schedule released
Form 8978, Partner’s Audit Liability Under Section 6226 Form 8978, Schedule A, Partner’s Imputed Underpayment (Supplemental) The IRS has released …
Partnership was not a domestic partnership in outbound transfer of intangibles
Chief Counsel Advice 201917007 In a redacted Chief Counsel Advice (CCA), IRS has determined that it had the authority under Reg …
IRS withdraws old, issues new, proposed partnership audit regs
Proposed Regs, Centralized Partnership Audit Regime IRS has withdrawn certain portions of proposed regs implementing the centralized partnership audit regime …