News & Analysis as of

Bipartisan Budget Act Internal Revenue Service

Latham & Watkins LLP

IRS Launches New Large Partnership Audits, Relying on AI and Increased Funding

Latham & Watkins LLP on

The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

Holland & Knight LLP on

The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Rivkin Radler LLP

Private Foundations, Closely Held Businesses, And Distribution Requirements

Rivkin Radler LLP on

“Show Me the Money”- Much has been written in recent months about how well the investment portfolios of private foundations have performed over the last several years. For example, a study conducted by the Council on...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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Are Your Employee Benefits Plans Ready for the New Year or Is It the Same Auld Lang Syne?

Holiday season and the end of the year are both quickly approaching, and with the turning of the calendar from 2021 to 2022 come several employee benefit plan amendment deadlines and implementation requirements. Some of these...more

Morrison & Foerster LLP

The Impending Large Partnership Audits

In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more

Bracewell LLP

IRS Provides Welcome Guidance on Code Section 45Q Credits in Revenue Ruling 2021-13

Bracewell LLP on

On July 1, 2021, the Internal Revenue Service (IRS) released Revenue Ruling 2021-13 (the Revenue Ruling), addressing the application of section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q) to carbon...more

Gray Reed

Is Your Partnership IRS Audit Ready?

Gray Reed on

The Bipartisan Budget Act (BBA) was signed into law by President Barack Obama in 2015 and fundamentally changed the way partnerships are audited. Under the BBA, the IRS generally assesses and collects any understatement of...more

Bracewell LLP

Broad Federal Support for Carbon Capture, Utilization and Storage May Lead to Greater Investment

Bracewell LLP on

Federal support for carbon capture, utilization and storage (“CCUS”) demonstrated over the last two months has generated even greater enthusiasm for carbon capture projects in the United States. First, in the final weeks of...more

Bracewell LLP

Treasury Releases Final Regulations on Carbon Capture Credits

Bracewell LLP on

On January 6, 2021, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) under section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q),...more

Eversheds Sutherland (US) LLP

Section 45Q carbon capture and sequestration final regulations released

On January 6, 2021, the Internal Revenue Service and the Department of the Treasury released final regulations on the IRC section 45Q carbon capture and sequestration (CCS) credit in order to implement changes made to that...more

Foster Garvey PC

Get Ready – The Internal Revenue Service May Be Knocking on Partnership Doors Next Year

Foster Garvey PC on

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 impacted: (i) the manner in which entities taxed as partnerships are...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Eversheds Sutherland (US) LLP

Ready, Set, Sequester? An updated guide to the Section 45Q Carbon Capture and Sequestration Credit Guidance

Section 45Q, as amended by the Bipartisan Budget Act of 2018 (BBA), provides a substantial tax credit for the capture and sequestration of carbon dioxide and other carbon oxides. Taxpayers have been awaiting guidance from the...more

McGlinchey Stafford

CARES Act Updates Tax Act’s Depreciation Period – Act Fast

McGlinchey Stafford on

Before the enactment of the 2017 Tax Cuts and Jobs Act (TCJA), qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property had a 15-year recovery period for depreciation...more

Bracewell LLP

Treasury Releases Long-Awaited Proposed Regulations under Section 45Q

Bracewell LLP on

On May 28, 2020, the Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which provides a credit for the capture...more

A&O Shearman

IRS Guidance Clarifies CARES Act Relief Procedures for Partnerships

A&O Shearman on

The CARES Act, enacted on March 27, 2020, provides important relief for partnerships including a correction to the bonus depreciation rules for qualified improvement property (QIP) under Section 168(e) and relief relating to...more

Dickinson Wright

Relief for Partnerships

Dickinson Wright on

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) offers tax relief which may be beneficial to entities taxed as partnerships. These provisions include (i) retroactive relief for entities taxed as...more

Morgan Lewis

IRS Releases Tax Return Amendment Relief for BBA Partnerships

Morgan Lewis on

The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more

Maynard Nexsen

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

Maynard Nexsen on

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

McDermott Will & Emery

Weekly IRS Roundup January 27 – 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 27 – 31, 2020. January 27, 2020: The Joint Committee on Taxation released a report...more

Patterson Belknap Webb & Tyler LLP

Planning for 2020: Changes to Hardship Distribution Rules and Amendment Deadlines

On September 23, 2019, the Department of Treasury published the final regulations relating to changes to the hardship distribution rules that apply to qualified retirement plans and 403(b) plans, that were enacted under the...more

Flaster Greenberg PC

New Retirement Plan Hardship Distribution Rules: What You Need to Know

Flaster Greenberg PC on

The IRS recently amended the rules applicable to hardship distributions from 401(k) and 403(b) plans. The new hardship distribution regulation relaxes some of the restrictions on the availability of hardship distributions...more

Snell & Wilmer

IRS Issues Final Regulations for Hardship Distributions

Snell & Wilmer on

We previously reported on the Bipartisan Budget Act (the “Budget Act”) hardship distribution rule changes for qualified retirement plans. On September 23, 2019, the IRS issued final regulations implementing certain statutory...more

92 Results
 / 
View per page
Page: of 4

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide