News & Analysis as of

Bipartisan Budget Internal Revenue Service

BakerHostetler

New Proposed Regulations Turn Off the Centralized Partnership Audit Rules in Certain Cases and Provide Guidance on QSub Partners

BakerHostetler on

On Nov. 20, 2020, the IRS and Treasury Department released proposed regulations on the centralized partnership audit rules enacted as part of the Bipartisan Budget Act of 2015 (the BBA Rules). The proposed regulations allow...more

Kramer Levin Naftalis & Frankel LLP

Hardship Distributions – IRS Clarifies Bipartisan Budget Act of 2018

The Bipartisan Budget Act of 2018 (BBA) made several changes with respect to Section 401(k) and 403(b) plans. The IRS recently issued a proposed amendment to the hardship distribution regulations to reflect the changes that...more

Troutman Pepper

Proposed IRS Regulations for Hardship Distributions Offer Welcome Guidance

Troutman Pepper on

Included in the February 2018 Bipartisan Budget Act were important changes to the hardship withdrawal rules for defined contribution plans (401(k) and 403(b) plans) and a directive ordering the Treasury Department to modify...more

Foley & Lardner LLP

IRS Issues New Guidance on Beginning Construction Requirement For ITC

Foley & Lardner LLP on

The IRS recently issued Notice 2018-59 (the “Notice”) which provides clarification to “beginning of construction” for taxpayers seeking to take advantage of the section 48 renewable electricity investment tax credit (ITC) for...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

WilmerHale on

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

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

BakerHostetler on

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

Eversheds Sutherland (US) LLP

Opting-In: Treasury Regulations Provide Rules for Electing into the New Partnership Audit Regime Early

As reported in a prior Sutherland Legal Alert, the Bipartisan Budget Act of 2015 (the 2015 Budget Act) makes significant changes to the procedural rules governing federal income tax audits and judicial proceedings that apply...more

Dickinson Wright

New IRS Audit Rules: Is Your Healthcare LLC Ready?

Dickinson Wright on

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

Foster Garvey PC

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

Foster Garvey PC on

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

McCarter & English, LLP

Health Law Insights Newsletter - Issue 9 - May 2016

NATIONAL - Medicare Proposes New Part B Payment System - The Center for Medicare and Medicaid Services (CMS) on April 27 proposed a new rule that would transform Medicare Part B reimbursement to practitioners into...more

Latham & Watkins LLP

IRS Issues Additional Guidance on “Begun Construction” Requirement for Wind Energy Credits

Latham & Watkins LLP on

Latest guidance extends “continuity safe harbor” to four years and includes other taxpayer-friendly modifications and clarifications to existing guidance. On May 5, 2016, the Internal Revenue Service (IRS) issued...more

Carlton Fields

Partnerships Must Respond to New Audit Rules

Carlton Fields on

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

Smith Anderson

New Partnership Tax Audit Rules

Smith Anderson on

The Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such...more

K&L Gates LLP

IRS Sets Short Fuse for Comments, Guidance on New Partnership Audit Rules

K&L Gates LLP on

As if it wasn’t going to be busy already, the Internal Revenue Service (“IRS”) has set Tax Day, April 15, 2016, as the due date for comments on significant new partnership audit rules. This new law, which was enacted as part...more

Dechert LLP

Partnership Audits of Private Equity Firms on the Rise

Dechert LLP on

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

Bradley Arant Boult Cummings LLP

Changes to IRS Partnership and LLC Rules

You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The IRS will be ramping up its...more

Foley Hoag LLP

Partnership Audit Regime Shakeup

Foley Hoag LLP on

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

Allen Matkins

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

Allen Matkins on

One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...more

Dechert LLP

Navigating the New Partnership Audit Rules: Sea Change or Same Course?

Dechert LLP on

The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more

Cozen O'Connor

New Partnership Audit Rules Require Careful Review of Partnership and LLC Agreements

Cozen O'Connor on

If you are a partner of a partnership or a member of a limited liability company (LLC) taxed as a partnership, or are entering into a new partnership or LLC, you may have some important decisions to make in light of impending...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Major Changes to Tax Audit Procedures to Impact Most Partnerships"

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

Holland & Knight LLP

New Audit Rules Require Changes to Partnership and LLC Operating Agreements

Holland & Knight LLP on

The Bipartisan Budget Act of 2015 (P.L. 114-74) includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships, including limited liability companies (LLCs) taxed as...more

36 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide