News & Analysis as of

K-1

What Practitioners Need to Know about the New Partnership Audit Rules

As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more

Tax Reporting for Grantor Trusts

Typically, a trust must file a separate income tax return for each calendar year. However, for most grantor trusts, filing a separate tax return is optional. The general rule and the alternative methods of reporting are...more

Business, Partnership and Estate and Trust Tax Returns and Identity Theft

by Pessin Katz Law, P.A. on

In Fact Sheet 2017-10 issued by the Internal Revenue Service (“IRS”) on July 25, 2017, “Information on Identity Theft for Business, Partnerships and Estate and Trusts”, the IRS points out that business, partnerships and...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

In Dispute Over Partnership’s Conversion to LLC, Court Finds No Duty to “Spoon-Feed” Sophisticated Investor

by Farrell Fritz, P.C. on

Pay attention to your K-1s or they may come back to bite you, is the lesson of Bruder v Hillman, Docket No. A-5055-15T1 [N.J. Super. Ct. App. Div. June 27, 2017], decided last week by a New Jersey appellate panel which...more

Tax Update, Volume 2017, Issue 2

by Pepper Hamilton LLP on

THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

Practical Partnership Tips: Electronic K-1s and Addressing New Partnership Audit Rules: Tax Update Volume 2017, Issue 2

by Pepper Hamilton LLP on

Partnerships and limited liability companies should begin thinking about addressing the issues presented by the new partnership law in their agreements, even if further changes will be necessary once regulations are issued....more

No Seriously, When is My Return Due?

It’s that time of the year again. Or maybe it isn’t. Effective for tax years beginning on or after December 31, 2015, the filing deadlines for many common federal tax returns have changed. As a result, taxpayers coming...more

IRS Clarification Causes Many Partnerships to Change Compensation Reporting for Partners

by Clark Hill PLC on

A federal tax issue frequently arises when key employees of an operating business are given the opportunity to become equity holders. Despite the well-established rule that partners of a partnership are not permitted to be...more

Could your Oil and Gas Interest Cause You to Be Responsible for Multiemployer Plan Withdrawal Liability?

I noticed an interesting case from the Tenth Circuit which found that a two to three percent working interest in an oil and gas venture could generate self-employment income for the owner of that interest. The individual in...more

No Obligation to File Inaccurate Return to Avoid Failure to File Penalty

by Charles (Chuck) Rubin on

A partnership was a partner in a Cayman Islands partnership - that investment made up most of its assets. The Cayman Islands partnership did not file a Form 1065 income tax return and did not give a Form K-1 to the taxpayer...more

Individuals Granted Profits Interests Are Treated as Partners, Not Employees

by Reed Smith on

The Internal Revenue Service (the “IRS”) issued temporary and final regulations, effective May 4, 2016, clarifying the employment tax treatment of partners in a partnership that owns a disregarded entity (the “Final...more

Divorce and K1 Adjustment of Status

by Ronald Shapiro on

Recipients of a fiancé visa, officially known as a K-1 visa are required to marry only their United States’ citizen petitioner. After the marriage, the foreign citizen must then file for an adjustment of status within 90 days...more

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

by Garvey Schubert Barer 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 impacts: (i) the manner in which entities taxed as partnerships will be...more

Marrying a U.S.Citizen: Which Visa is Right for You?

by Ronald Shapiro on

When United States citizens and foreign-born individuals decide to tie the knot, there can be a variety of obstacles that get in the way. While things like language barriers, religious customs and cultural misunderstandings...more

Be Careful in Granting Profits Interests to Your Key Employees; New IRS Regulations Suggest the IRS is Keen on Form K-1 Filing

by Locke Lord LLP on

On May 5, 2016, the Department of Treasury and the Internal Revenue Service published final and temporary regulations amending Treasury Regulations §301.7701-2 under Section 7701 of the Internal Revenue Code of 1986, as...more

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

by K&L Gates LLP on

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

Top Five Challenges to Gaining a K-1 Visa

by Ronald Shapiro on

The total number of K-1 visa applications in 2015 was just under 44,000. 31,000 of these were approved. So, a majority of K-1 visas are granted, but a significant amount are denied. Fortunately, nearly 7,000 were approved on...more

New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection of Taxes Relating to Partnership Activities

by Shearman & Sterling LLP on

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

K-1 Visa Program Under Federal Investigation

by Ronald Shapiro on

K-1 fiance visas offer an option for family-based immigration visas that may require less paperwork and  filing fees than spousal visas. Compared to spousal visas that can take up to two years, fiance visas only take five to...more

Immigration Law Updates - January 5, 2016

by Cohen & Grigsby, P.C on

Following are recent and/or anticipated changes to United States immigration laws, which may impact our clients: Proposed Changes to the Visa Waiver Program Following Terror Concerns - In the aftermath of the Paris...more

Responsibility for Deficiencies Will Shift to Partnerships Under New Audit Rules

by BakerHostetler on

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

New Tax Audit Regime Constitutes a Sea Change for Partnerships

by Latham & Watkins LLP on

Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect. The Bipartisan Budget Act of 2015 (the Act), which President Obama...more

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Sweeping Change to Partnership Tax Audit Procedures

by Stinson Leonard Street on

A major change to partnership audits was signed into place by President Barack Obama on November 2nd following the passage of the Bipartisan Budget Act of 2015 by Congress on October 30th. Previously, partnerships with more...more

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