TEFRA

News & Analysis as of

Healthcare Newsletter: Volume 6, Number 1

Recent Developments in Mental Health Benefit Denials - The Mental Health Parity and Addiction Equity Act (Parity Act) requires health plans to provide the same coverage for mental health conditions as they provide for...more

New IRS Audit Rules: Is Your Healthcare LLC Ready?

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

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

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

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

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

Predicting How the New Partnership Audit Rules Will Affect S Corporations and Their Shareholders

This column has three focal points: S corporations (of course!), the new partnership audit procedures and Jeanne Dixon. Yes, that Jeanne Dixon—the self-professed psychic who claimed to have predicted the assassination of...more

Shelf Registration Extended Offering Period: Ready for the Municipal Marketplace?

Recently, a significant municipal issuer entered the market with its first sale under a $1 billion borrowing program that will use an offering statement style novel to the municipal market. For years, issuers of traditional...more

Five Things You Need to Know Now About the New Partnership Audit Rules

Currently, most federal income tax audits of partnerships are governed by TEFRA, the Tax Equity and Fiscal Responsibility Act of 1982. In the simplest terms, TEFRA provides for a partnership audit to be conducted at the...more

How the Change in IRS Partnership Audit Rules will Impact Partnerships and LLCs

With the Bipartisan Budget Act of 2015, H.R. 1314 (the “Act”), enacted on November 2, 2015, Congress has introduced some major changes affecting partnerships (including LLCs taxed as partnerships), replacing the current Tax...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

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

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

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

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

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

HHS Psychiatric Hospital Reimbursement Methodology Upheld

On December 29, 2015 the U.S. Court of Appeals for the District of Columbia rejected a challenge to a psychiatric hospital's pre-PPS Medicare reimbursement. Washington Regional Medicorp v. Burwell, No. 1:13-cv-00622 (D.C....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

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

Congress Passes New Partnership Audit Rules - The Bipartisan Budget Act of 2015

On November 2, President Obama signed the Bipartisan Budget Act of 2015 into law, which brought sweeping changes to the partnership audit rules. The act repeals the substantive tax provisions and voluntary centralized audit...more

Responsibility for Deficiencies Will Shift to Partnerships Under New Audit Rules

Effective for tax years beginning after December 31, 2017, any additional tax or penalties resulting from a partnership audit will be assessed and collected at the partnership level in the year the audit is completed....more

Early Analysis of New Partnership Audit Rules’ Impact on LIHTC Transactions

The Bipartisan Budget Act of 2015 (P.L. 114-74) was signed into law on Nov. 2, 2015. The Act includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships, including...more

Comprehensive Overhaul of Partnership Audit Regime

On November 2, 2015, the Bipartisan Budget Act significantly overhauled the audit regime applicable to U.S. and certain non-U.S. investment fund vehicles that are taxed as partnerships for U.S. federal income tax purposes. In...more

New Audit Rules for Partnerships

Last week, President Obama signed into law the Bipartisan Budget Act of 2015.  Buried in this budget bill is an entirely new procedure for how partnerships are audited.  Specifically, it would repeal the  much maligned TEFRA...more

Goodbye TEFRA, Hello New Partnership Audit Rules

Last week, President Obama signed into law the Bipartisan Budget Act of 2015. As I mentioned in a prior post, the budget bill contained a proposal to revamp how partnerships are audited. Specifically, TEFRA (the 1982 Tax...more

Partnership Audit Reform Passed into Law

On Monday, November 2, President Obama signed the Bipartisan Budget Act of 2015 (the “BBA”) into law, effecting sweeping changes to the rules governing audits of entities treated as partnerships for U.S. federal income tax...more

Last Week's Budget Bill Drastically Changed the Audit Rules for Partnerships

Last week, President Obama signed into law the Bipartisan Budget Act of 2015. While there has been news coverage about the budget agreement, little attention has been paid to the fact that it dramatically changed the manner...more

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