On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more
9/13/2023
/ Enforcement Actions ,
Estate Planning ,
Inflation Reduction Act (IRA) ,
Investment Management ,
IRS ,
Offshore Funds ,
Partnerships ,
Private Equity ,
TEFRA ,
Trustees ,
Wealth Tax
Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
11/5/2015
/ Administrative Procedure Act ,
Audits ,
Barack Obama ,
Bipartisan Budget ,
Burden of Proof ,
Business Taxes ,
C-Corporation ,
FPAA ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
K-1 ,
New Legislation ,
Partnership Interests ,
Partnerships ,
S-Corporation ,
Statute of Limitations ,
Tax Assessment ,
TEFRA ,
Treasury
In United States v. Woods,1 the U.S. Supreme Court ruled unanimously for the government on two long-brewing disagreements over penalty jurisdiction in the partnership context and over the breadth of valuation misstatement...more