As I previously discussed, the IRS released last week long awaited regulatory guidance addressing the new partnership audit rules. The status of these proposed regulations is unclear, though, as the IRS officially withdrew...more
The IRS released a flurry of new rules as the Obama administration came to a close. The attached presentation provides an overview of many of these developments in the partnership and real estate tax area, including a...more
1/25/2017
/ Audits ,
Books & Records ,
C-Corporation ,
Conversion Requirements ,
Disregarded Entities ,
Foreign Entities ,
Partnerships ,
Push-Out Requirements ,
REIT ,
S-Corporation ,
Trusts
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
At a tax conference yesterday, a Treasury official indicated that Treasury is working hard to finalize regulations before the 60-day freeze that occurs before the inauguration of a new president (Treasury will not issue final...more
As previously discussed, TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.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
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
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
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
The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited. Specifically, it would repeal the much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules....more