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Proposed Regs, Centralized Partnership Audit Regime IRS has withdrawn certain portions of proposed regs implementing the centralized partnership audit regime …
IRS finalizes central partnership audit partnership representative and early adoption regs
T.D. 9839, Partnership Representative under the Centralized Partnership Audit Regime and Election to Apply the Centralized Partnership Audit Regime IRS …
IRS finalizes rules for electing out of centralized partnership audit regime
IRS has issued final regs regarding the election out of the centralized partnership audit regime rules. The final regs largely …
2017 Tax Reform: Checkpoint Special Study on S corp, partnership & other changes in the “Tax Cuts and Jobs Act”
On December 22, President Trump signed into law H.R. 1, the “Tax Cuts and Jobs Act,” a sweeping tax reform …
Penalty relief provided for partnerships filing late in 2017 due to new deadline
In a Notice, IRS has provided penalty relief to partnerships that filed certain untimely returns, or untimely requests for an …
Proposed regs on new partnership uniform audit rules: “Push out” election
IRS has issued 277 pages of proposed regs on the new partnership audit regime that was enacted as part of …