Partnerships Limited Liability Company

News & Analysis as of

Changes to IRS Partnership and LLC Audit Rules

Recent history has seen a proliferation of health care organizations—including tax-exempt organizations, for-profit companies, and physician practice groups—that have joined together to take advantage of different synergies...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

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

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

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Effective for partnership tax years beginning after 2017, the Bipartisan Budget Act of 2015 repealed the current partnership audit rules and replaced them with rules described in general terms below.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

IRS Audits of Partnerships: Big Changes are Coming

The Bipartisan Budget Act of 2015 (the “Act”), which was signed into law on November 2, will drastically change the way entities (including limited liability companies) treated as partnerships for U.S. federal income tax...more

Sweeping Change to Partnership Tax Audit Procedures

A major change to partnership audits was signed into place by President Barack Obama on November 2nd following the passage of the Bipartisan Budget Act of 2015 by Congress on October 30th. Previously, partnerships with more...more

Spotlight On Alabama: A Busy Tax Year in Review

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Recent UK Court Decision on UK Tax Treatment of US LLCs

HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners. Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more

IRS to Provide New Exception to Partnership Formation Nonrecognition When There Are Foreign Partners

In Notice 2015-54, the IRS indicates it will be issuing regulations under Code Section 721(c) which will provide that transfers of appreciated property to controlled partnerships that have a related foreign partner will not...more

New Restrictions on Transferring Appreciated Property to Partnerships With Related Foreign Partners

The IRS issued Notice 2015-54 stating that it plans to issue regulations under Section 721(c) to ensure that U.S. taxpayers do not use partnerships to shift built-in gains to non-U.S. affiliates. In 1997 Congress authorized...more

How Do I Get Out of this Practice?

For years the goal of many young doctors was to gain ownership in their medical practice entity. For many, when the time came for them to “make partner,” they signed on the dotted line without fully understanding the legal...more

Funding a Partnership

One of the primary advantages of a partnership (or limited liability company) over a corporation is the flexibility to structure the business deal. Rather than having to deal with unwieldy units of stock or other ownership...more

Summary of IC-DISC Tax Benefits

Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

In Business & Corporate Law Avoiding a Messy Business Divorce is Important! #BusinessAttorney

When people come together to begin a business, they may not think the time will come when they will not get along. But if, after many years, you and your business partner no longer see eye-to-eye when it comes to how to...more

The Ins And Outs Of Joint Venture Agreements

In this presentation: - What is a joint venture? - Advantages and disadvantages of using a joint venture - Starting a joint venture - Step 1: Find the right partner - Step 2: Ensure the JV...more

New Guidance on Historical Rehabilitation Credits May Indicate Tougher Safe Harbors for Other Investment Tax Credits in the Future

On December 30, 2013, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (the “HRC”) among partners in a...more

10 MLP Governance Facts

MLPs possess unique governance characteristics as compared to corporations.The number of master limited partnerships (MLPs) has grown significantly over the past five years, increasing from 59 in 2009 to over 100 in 2013. An...more

Representing Physicians: Life Cycle of a Physician-Practice & Physician Integration Options (Presentation)

In This Presentation: - General Considerations - Who is Your Client? - Who Can Employ a Physician? - Basic Issues in Employment Contracts - The Buy-In: Becoming an Owner in a Medical Practice -...more

Addressing Sale Proceeds In The Face Of Guaranty "Carve-Out" Provisions

Commercial loans to closely held business entities, such as an LLC or partnership, typically include guaranties by the entity’s principal. Sometimes, the guarantor demands a “carve-out” to expressly exempt one or more of the...more

Protecting Your Project From Litigation: Limited Liability Company vs. Partnership

If you have multiple investors/owners, one of the benefits of using a Limited Liability Company (LLC) to own real property rather than using a partnership is that the LLC offers better protection of the real property from...more

Legislative Update: Business Law

I. GENERAL. A. Introduction. In selecting a form of business entity in Texas the organizer or initial owners can consider the following five business entity forms: • Corporation • General...more

Yankees' Lawyer on Manchester City MLS Partnership [Video]

June 18 (Bloomberg) -- Irwin Kishner, chairman of the executive committee and co-chairman of the corporate department at Herrick, Feinstein LLP, talks with Bloomberg Law's Spencer Mazyck about the New York Yankees' investment...more

Conversion Is Not So Easy, And So Smooth A Thing . . .

Entity conversions are a relatively new phenomena. The legislature first provided for conversion in 1999 when it enacted AB 197 (Ackerman). The conversion of partnerships and limited liability companies to other types of...more

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