News & Analysis as of

Audits Internal Revenue Service Limited Liability Company (LLC)

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Bradley Arant Boult Cummings LLP

With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

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State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Poyner Spruill LLP

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

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Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here to Stay: It’s Time to Act - Construction and Procurement Law News, Q2 2018

The January 1, 2018 effective date of the new federal partnership audit rules quietly came and went, with many of our partnership and LLC clients and their advisers hoping that the rules were just a bad dream or would at...more

Katten Muchin Rosenman LLP

Are You Ready for the New Partnership Audit Regime?

Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more

Chambliss, Bahner & Stophel, P.C.

New IRS Partnership/LLC Rules Require Your Immediate Action

New rules that change the way that partnership entities and limited liability companies are audited took effect on January 1, 2018. You may have received the legal update we sent on January 2, 2018....more

Davis Wright Tremaine LLP

Sweeping Changes to Partnership Audit Rules Warrant Changes to Existing Partnership and LLC Agreements

Sweeping changes to the rules governing federal income tax audits of partnerships went into effect this year. The new partnership audit rules (the “New Audit Rules”) apply for partnership tax returns for taxable years...more

McNees Wallace & Nurick LLC

IRS Gains At The Expense of Partnership Owners

The new partnership audit rules went into effect earlier this year. The new rules permit the IRS to assess and collect tax directly from a partnership or an LLC taxed as a partnership (both of these entities are, for...more

Whitman Legal Solutions, LLC

If One Musician Plays A Wrong Note, the Entire Orchestra Now May Pay the Price -- Be Aware of New Partnership Tax Audit Rules

In 1985, the “participatory journalist” George Plimpton worked as a temporary percussionist, playing sleigh bells, triangle, bass drum, and most notably, gong, with the New York Philharmonic. During a performance, he once...more

Miles & Stockbridge P.C.

How You May Be Affected by the Changes to Partnership Audit Rules

In 2015, Congress passed the Bipartisan Budget Act that created a new Centralized Partnership Audit regime that is effective for income tax returns filed of partnership taxable years beginning after December 31, 2017. These...more

WilmerHale

New Partnership Audit Rules in Effect; Partnerships and LLCs Should Consider Changes

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A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more

Jaburg Wilk

Partnership Audit Rules Have Changed Under New Tax Law

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Congress enacted the Bipartisan Budget Act of 2015 (“BBA”) under which existing partnership audit rules have been replaced. The new BBA audit rules are broad and complex and effective for partnership tax returns filed for tax...more

Cohen Seglias Pallas Greenhall & Furman PC

New IRS Partnership Audit Rules Take Effect Jan 1: What You Need to Know

On January 1, 2018, the rules and procedures relating to IRS audits of partnerships, including those limited liability companies taxed as partnerships, (for purposes here, collectively, the “Partnerships”) will change. The...more

Haynsworth Sinkler Boyd, P.A.

New IRS Audit Rules To Impact Partnerships (LLCs) In 2018

For tax years beginning after December 31, 2017, a new centralized audit regime for partnerships and LLCs will take effect. Currently, audit adjustments made by the Internal Revenue Service for partnerships (LLCs) are made at...more

Pullman & Comley, LLC

Partnerships and Limited Liability Companies Take Note: Significant Changes in IRS Audit Procedures Take Effect January 1, 2018

Pullman & Comley, LLC on

Under pre- 2018 rules, when a partnership (which for this Client Alert will include a limited liability company which is taxed as a partnership) was audited by the IRS, one of the partners acted as the “Tax Matters Partner”...more

Obermayer Rebmann Maxwell & Hippel LLP

Early New Year’s Resolution: Update Partnership and LLC Agreements to Comply with New IRS Audit Rules

In 2015, Congress repealed the complex and heavily criticized Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) partnership-level audit rules which apply to partnerships and most LLCs. The new audit rules, which...more

Epstein Becker & Green

Reminder: The New Partnership Audit Rules Are Effective for Tax Years Beginning January 1, 2018

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The Bipartisan Budget Act of 2015 (“BBA”), enacted on November 2, 2015, provided for sweeping changes to the way partnerships are audited, including the ability of the Internal Revenue Service (“IRS”) to levy U.S. federal...more

Farrell Fritz, P.C.

The New Partnership Audit & Collection Regime: Its Time Has Come

Farrell Fritz, P.C. on

Beginning 2018, the IRS is authorized to collect from a partnership any tax deficiencies arising out of the partnership’s operations for a taxable year, even if the persons who were partners in the year to which the...more

Dentons

A Summary of the Proposed Partnership Audit Regulations

Dentons on

This blog post is intended to identify the most material aspects of the proposed regulations the IRS has introduced to implement the BBA partnership audit rules, and provide guidance on what actions a partnership should...more

Carlton Fields

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

Carlton Fields on

A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

BakerHostetler

Preparing for the New Partnership Audit Rules

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The Bipartisan Budget Act of 2015 substantially changed audit-related rules impacting entities taxed as partnerships, including both state-law partnerships and many limited liability companies (LLCs). The most significant...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here: Are You Ready? - Construction and Procurement Law News, Q3 2017

The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more

Neal, Gerber & Eisenberg LLP

New IRS Rules for Partnership Audits Require Immediate Review of Partnership Agreements

Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more

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