2nd Circuit sides with government in limited partner tax dispute
The definition of “limited partner” for purposes of the self-employment tax exclusion hinges on a partner’s management and control activities, …
IRS Finalizes Rules to Ease Partnership Interest Sales Reporting
The IRS has issued final regs that permanently resolve a longstanding compliance problem by removing the requirement that partnerships furnish …
IRS Proposes to Ease Reporting Rules for Partnership Interest Sales
The IRS has proposed regs to delay and revise the reporting requirements for partnership interest exchanges, aiming to address compliance challenges and …
Centralized Partnership Audit Regime Muddied by IRS Uncertainty, Expert Says
The future of the IRS’ plans and ability to enforce partnership tax compliance pursuant to now 10-year-old legislation is uncertain …
Exempt Org Foreign Reporting Forms Burdensome, IRS Told
Several organizations responded to an IRS request for comment on filing obligations of tax-exempt entities to say that three forms …
Will the New Partnership Related Party Basis-Shifting Rules Survive?
Practitioner’s Tax Action Bulletin® Advisory In June 2024, the IRS released a guidance package on related party basis adjustments (RPBAs) …
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 …