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Audits Internal Revenue Service

IRS Large Business & International Division Rolls Out 11 Additional Compliance Campaigns For Audits

by Fox Rothschild LLP on

On Friday, November 3, 2017, the IRS Large Business and International division (LB&I) announced the identification and selection of 11 additional compliance campaigns. In January 2017, LB&I unveiled its first 13 campaigns to...more

The New Partnership Audit & Collection Regime: Its Time Has Come

by Farrell Fritz, P.C. on

Beginning 2018, the IRS is authorized to collect from a partnership any tax deficiencies arising out of the partnership’s operations for a taxable year, even if the persons who were partners in the year to which the...more

IRS Audits Of Cannabis Companies And The Importance Of Substantiation

by Fox Rothschild LLP on

Today, the Tax Court issued its opinion in Feinberg v. Commissioner, a case involving an ongoing and hard fought battle between the IRS and a medical marijuana dispensary, Total Health Concepts, LLC. The IRS examined THC’s...more

What REITs Need to Know About the New Partnership Audit Rules

by Goodwin on

The Bipartisan Budget Act of 2015 fundamentally changes the rules and procedures governing IRS audits of partnerships for taxable years beginning on or after January 1, 2018. These new rules are contained in new Sections...more

A Summary of the Proposed Partnership Audit Regulations

by Davis Brown Law Firm on

This blog post is intended to identify the most material aspects of the proposed regulations the IRS has introduced to implement the BBA partnership audit rules, and provide guidance on what actions a partnership should...more

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

by Carlton Fields on

A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

Preparing for the New Partnership Audit Rules

by BakerHostetler on

The Bipartisan Budget Act of 2015 substantially changed audit-related rules impacting entities taxed as partnerships, including both state-law partnerships and many limited liability companies (LLCs). The most significant...more

New Partnership Audit Regime and Partnership M&A Transactions

Background: - Congress has changed the way partnership audits will be conducted in the future. Beginning with tax years starting on or after January 1, 2018, audits will still be done at the partnership level; however...more

The New Partnership Audit Rules Are Here: Are You Ready? - Construction and Procurement Law News, Q3 2017

The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more

Staying Out of Trouble: How to Avoid IRS and DOL Audits

by McDermott Will & Emery on

The Internal Revenue Service (IRS) and the Department of Labor (DOL) conduct different types of benefit plan audits, such as retirement plans and health and welfare plans, and for various reasons. In a presentation, Jeffrey...more

No Gifts in Proposed Partnership Audit Regulations

by Pepper Hamilton LLP on

New partnership audit and collection regime rules will soon go into effect, defining who can elect out and enabling the Internal Revenue Service to assess taxes directly against the partnerships it audits. Originally...more

Inter-Company Pricing Practices of Taxpayers with Foreign Affiliates

by Dickinson Wright on

The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting information about...more

New IRS Rules for Partnership Audits Require Immediate Review of Partnership Agreements

Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more

Some Recent Tax Developments

by Pessin Katz Law, P.A. on

Over the past several months there have been a number of tax developments that might affect PK Law readers...more

Are You Ready for the New Partnership Audit Regime?

by Pessin Katz Law, P.A. on

The Bipartisan Budget Act of 2015 (129 Stat. 584, Public Law 114–74, Nov. 2, 2015, H.R. 1314) (the “Act”) contains a new partnership audit regime the implementation of which will begin for audits of partnership tax returns...more

Internal Revenue Service Updates Golden Parachute Payments Audit Technique Guide, Signaling Key Items IRS May Review on Audit

by McDermott Will & Emery on

In early 2017, the IRS updated its Golden Parachute Payments Audit Technique Guide for the first time since its 2005 issuance. While intended as an internal reference for IRS agents conducting golden parachute examinations,...more

Tax Talk: Volume 10, Issue 2

by Morrison & Foerster LLP on

EDITOR’S NOTE - With the failure of health care legislation to “repeal and replace” the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform. Since Congress plans to take August off, any real tax...more

New partnership audit rules can apply to partnerships, LLCs with only a few partners, members

by Thompson Coburn LLP on

Effective in 2018, changes in partnership audit rules may apply the following (and other) consequences to partnerships (including LLCs taxed as such)...more

The Costly Tax Consequences of ESOP Disqualification

by Davis Brown Law Firm on

Over the past several years, the IRS has renewed its focus on auditing Employee Stock Ownership Plans (ESOPs), in part because of allegedly abusive arrangements (for a quick overview, see Courtney’s ESOP post). Unfortunately,...more

Partnerships Prepare For New Audit Regime

by Cole Schotz on

On November 2, 2015, new partnership audit rules, repealing existing TEFRA rules, were enacted in Section 1101 of the Bipartisan Budget Act (“BBA”). On August 15, 2016, Treasury published temporary regulations (TD 9780, 81...more

New Partnership Audit Rules Apply Beginning January 1, 2018: Is Your Business Ready?

by K&L Gates LLP on

New partnership audit rules will be effective for audits of tax years beginning in 2018. Proposed Treasury Regulations have been released and are expected to be finalized in the next few months. (The comment period is open...more

IRS Issues Guidance To Examiners Handling BBA Partnership Audits

by Fox Rothschild LLP on

As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships are subject to a...more

Audits of Multifamily Housing Bonds Triggered by Failure to File Form 8703

IRC Section 142(d) requires operators of qualified residential rental properties to file Form 8703, Annual Certification of a Residential Rental Project annually. A number of recent audits of multifamily housing bonds appear...more

Significant Changes to Partnership Tax Audits Coming in 2018

by Blank Rome LLP on

In less than six months, on January 1, 2018, the new centralized partnership audit rules enacted by Congress as part of the Bipartisan Budget Act of 2015 (“BBA”) will go into effect. The new rules were drafted in response to...more

IRS gets upper hand in S corporation compensation audits

by Thompson Coburn LLP on

Any compensation the owner receives is subject to FICA tax, which imposes an equivalent burden. And the IRS frequently attacks owners who receive cash distributions from an S corporation, arguing that the distributions were...more

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