The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more
6/21/2017
/ Audits ,
Bipartisan Budget Act ,
IRS ,
Limited Liability Company (LLC) ,
Local Taxes ,
Partnerships ,
Proposed Regulation ,
Regulatory Freeze ,
TEFRA ,
Trump Administration ,
UPREITS
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions