Partnerships

News & Analysis as of

What Are the New Partnership Audit Rules?

The recently enacted Bipartisan Budget Act of 2015 amended the existing rules governing tax audits of partnerships in the U.S. Who Does this Effect and When? The new rules primarily impact partnerships with more...more

Partnership Audit Regime Shakeup

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

New IRS Audit Rules: Partnerships and LLCs Should Name A Partnership Representative For IRS Audits

New legislation will govern IRS audits of partnerships and LLCs for tax years beginning after December 31, 2017. The new rules will affect both existing LLCs and partnerships as well as new partnership and LLC agreements,...more

Electing into New Partnership Audit Rules

As previously discussed, TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018. The new audit rules...more

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

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

IRS Concludes Upper-Tier Disregarded Entity is Continuation of Historical Partnership

The IRS favorably ruled that an internal partnership restructuring was essentially a “nothing” for tax purposes even though the transaction moved the tax-regarded partnership to a different state-law entity. Specifically, in...more

New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection of Taxes Relating to Partnership Activities

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, includes sweeping changes to the rules governing federal tax audits of entities treated as partnerships for US federal income tax...more

Budget Act of 2015 Alert

New Partnership Audit Rules Will Impact New and Existing Partnership Agreements - The Bipartisan Budget Act of 2015 will change significantly the audit, assessment, and collection procedures applicable to entities...more

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

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

"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

ESG Capital Partners v. Passport Special Opportunities Master Fund, C.A. No. 11053-VCL (Del. Ch. Dec. 16, 2015) (Laster, V.C.)

In this memorandum opinion, the Court of Chancery granted in part and denied in part defendants’ motion to dismiss a complaint seeking declaratory relief in which plaintiffs alleged that certain investors in ESG Capital...more

A Buyer’s Market for MLPs in 2016

Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships....more

Federal Tax Advisory: Investment Company Rules

Sections 351 and 362 contain investment company rules that have nothing to do with mutual funds. They define certain corporations as investment companies in counterintuitive ways and then deny the usual nonrecognition...more

District Court Explains When Suit Is Direct Or Derivative In The Alternative Entity Context

Whether a claim is direct or derivative often determines if it will survive a motion to dismiss. Who would get the benefit of a recovery is one test applied to make that decision. But in the context of a partnership, that...more

MAS consults on 2016/17 business plan

MAS has issued a consultation on its draft business plan for 2016/17 and three-year corporate strategy. The aims are based on six core areas...more

Comprehensive Partnership Audit Reform Requires Amendments To Partnership (and LLC Operating) Agreements

Congress has recently scrapped the existing procedures for IRS audits of partnerships. The new rules (the “BBA Audit Rules”1) are effective for partnership taxable years beginning on or after January 1, 2018. A partnership...more

Recent revisions to partnership audit rules will affect existing and future tax partnerships

Congress recently passed the Bipartisan Budget Act of 2015. Among its revenue-raising provisions is a repeal of the current tax matters partner (TMP) rules with regard to tax audits of, and tax adjustments concerning,...more

PATH Act takes taxpayer-friendly approach in amending and clarifying partnership audit and litigation procedures

President Obama has signed into law tax extenders legislation, entitled the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act), which will extend more than 50 expiring provisions of the Internal Revenue Code. ...more

New Audit Rules Require Changes to Partnership and LLC Operating Agreements

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

Jerry Lucente Speaks

Jerry Lucente is a Small Business/Self Employed Territory Manager with the North Atlantic Region of IRS, which includes the six New England states, New York and New Jersey. He is responsible for four groups at IRS that...more

High Net Worth Family Tax Report, Vol. 10, No.3

Don’t Forget Year-End Gifts, etc. - A variety of planning steps should be considered before the end of the year. One of these is to make any $14,000 annual exclusion gifts you wish to make. This annual exclusion amount...more

New Act Significantly Alters Partnership Audit Procedures

The recently enacted Bipartisan Budget Act of 2015 repeals the current Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and Electing Large Partnership (ELP) partnership audit regimes and replaces them with a new...more

The Game Has Changed: Congress Enacts Changes to IRS Partnership Audit Rules That Could Force Partnerships to Pay Tax - Tax Update...

The Bipartisan Budget Act will allow the IRS to collect taxes associated with audit adjustments at the partnership level, rather than passing adjustments through to the individual partners, effectively imposing entity-level...more

New Partnership Audit Rules Impact Both Existing and New Partnership and LLC Operating Agreements

On November 2, 2015, President Barack Obama signed the Bipartisan Budget Act of 2015 (the Act) into law, instituting for tax years commencing after 2017 significant changes to the rules governing federal tax audits of...more

Bipartisan Budget Act of 2015 Introduces New Partnership IRS Audit Rules

Effective for partnership tax years beginning after 2017, the Bipartisan Budget Act of 2015 repealed the current partnership audit rules and replaced them with rules described in general terms below. Partnerships can also...more

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