News & Analysis as of

Limited Liability Company (LLC) TEFRA

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

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

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

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...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In 2015, Congress repealed the complex and heavily criticized Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) partnership-level audit rules which apply to partnerships and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

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

Partridge Snow & Hahn LLP

Holding the Bag: Update Your Operating Agreement or Face the Tax Consequences

New Law – Direct Assessment of LLC Tax Liability - The Tax Equity and Fiscal Responsibility Act (“TEFRA”) has governed the procedures for auditing partnerships since 1982. Under TEFRA, if the IRS audited an LLC taxed as a...more

Bradley Arant Boult Cummings LLP

July 2017 Federal Tax Alert – New Partnership Audit Regulations

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) recently reissued 277 pages of proposed regulations and a preamble (REG-136118-15) regarding the new centralized partnership audit rules enacted as part of...more

Dechert LLP

Reissuance of Proposed Regulations on Partnership Audit Rules

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

Morrison & Foerster LLP

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

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

Neal, Gerber & Eisenberg LLP

IRS Issues Guidance to Partnerships Opting-In to New Partnership Audit Regime

The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...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

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

Cozen O'Connor

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

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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

Locke Lord LLP

Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and Hedge Funds

Locke Lord LLP on

On November 2, 2015, the United States Congress enacted the Bipartisan Budget Act of 2015 (the Act) to fund the federal government. Among other provisions, the Act significantly modifies how the Internal Revenue Service (IRS)...more

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