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Audits Business Taxes

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

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What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Foodman CPAs & Advisors

Auditoría Comercial Del IRS

El IRS se centra en las empresas desde la aprobación de la Ley de Reducción de la Inflación. Según el Plan Operativo Estratégico (financiado por la Ley de Reducción de la Inflación), el IRS está aumentando las tasas de...more

Foodman CPAs & Advisors

IRS Business Audit

IRS is focused on Businesses since the passage of the Inflation Reduction Act. Under the Strategic Operating Plan (funded by the Inflation Reduction Act), the IRS is increasing audit rates, expanding enforcement and targeting...more

Latham & Watkins LLP

New IRS Unit Leverages AI to Step Up Partnership Audits; Hundreds of New Inquiries Expected

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The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Balch & Bingham LLP

Three Ways Businesses Can Prepare For A Sales And Use Tax Audit To Maximize Potential Savings

Balch & Bingham LLP on

"[I]n this world nothing can be said to be certain, except death and taxes." Many of us are familiar with this famous statement by Benjamin Franklin, and the sentiment expressed then also remains true today. The thing about...more

Bradley Arant Boult Cummings LLP

With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more

Proskauer - Tax Talks

Summary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposals

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On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

International Lawyers Network

Establishing A Business Entity In Liechtenstein (Updated)

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

Maynard Nexsen

Is Your Partnership Ready for the IRS's New Centralized Audit Regime?

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The new centralized audit regime for partnerships established by the Bipartisan Budget Act of 2015 (“BBA”) has been in effect since January 1, 2018, but is your partnership or LLC treated as a partnership for tax purposes...more

International Lawyers Network

Establishing A Business Entity In Liechtenstein

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

Katten Muchin Rosenman LLP

Electing Out of the New Partnership Rules

Beginning in 2018, partnerships (meaning an entity treated as a partnership for tax purposes) generally are subject to the new partnership audit rules. Partnerships may elect out of the new partnership audit rules if they (1)...more

Poyner Spruill LLP

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

Poyner Spruill LLP on

Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Burr & Forman

Don’t Forget to Update Your Operating Agreement for Partnership Audit Rule Changes

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The Bipartisan Budget Act of 2015 enacted sweeping changes to the federal audit regime for entities taxed as partnerships. The new audit rules became effective for tax years beginning on or after January 1, 2018. For tax...more

Katten Muchin Rosenman LLP

Are You Ready for the New Partnership Audit Regime?

Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more

Bracewell LLP

Application of Partnership Audit Rules to Private Funds

Bracewell LLP on

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...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

Jaburg Wilk

Partnership Audit Rules Have Changed Under New Tax Law

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Congress enacted the Bipartisan Budget Act of 2015 (“BBA”) under which existing partnership audit rules have been replaced. The new BBA audit rules are broad and complex and effective for partnership tax returns filed for tax...more

Cohen Seglias Pallas Greenhall & Furman PC

New IRS Partnership Audit Rules Take Effect Jan 1: What You Need to Know

On January 1, 2018, the rules and procedures relating to IRS audits of partnerships, including those limited liability companies taxed as partnerships, (for purposes here, collectively, the “Partnerships”) will change. The...more

Alston & Bird

Proposed Tax Regulations Address International Aspects of the New Partnership Audit Regime

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We are about to witness an almost unprecedented centralized partnership audit regime that takes full effect for taxable years starting on or after January 1, 2018, as adopted in late 2015 by Section 1101 of the Bipartisan...more

Pullman & Comley, LLC

Partnerships and Limited Liability Companies Take Note: Significant Changes in IRS Audit Procedures Take Effect January 1, 2018

Pullman & Comley, LLC on

Under pre- 2018 rules, when a partnership (which for this Client Alert will include a limited liability company which is taxed as a partnership) was audited by the IRS, one of the partners acted as the “Tax Matters Partner”...more

Epstein Becker & Green

Reminder: The New Partnership Audit Rules Are Effective for Tax Years Beginning January 1, 2018

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The Bipartisan Budget Act of 2015 (“BBA”), enacted on November 2, 2015, provided for sweeping changes to the way partnerships are audited, including the ability of the Internal Revenue Service (“IRS”) to levy U.S. federal...more

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