News & Analysis as of

Limited Liability Company (LLC) Business Taxes Audits

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

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

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

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

Poyner Spruill LLP

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

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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

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

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

Pullman & Comley, LLC

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

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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

Farrell Fritz, P.C.

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

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

Dentons

A Summary of the Proposed Partnership Audit Regulations

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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

Carlton Fields

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

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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

Dechert LLP

Reissuance of Proposed Regulations on Partnership Audit Rules

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The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

Hinshaw & Culbertson LLP

All Partnerships Need to Adapt to the New Partnership Audit Rules Now

Historically, partnerships and multiple-member limited liability companies ("LLCs") taxed as partnerships generally have not had to pay income taxes at the partnership level. As a result of federal tax law changes effective...more

Roetzel & Andress

IRS Announces Proposed Partnership Audit Regulations Which Impact Limited Liability Companies and Partnerships

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The Internal Revenue Service (IRS) has released Proposed Regulations under Section 1101 of the Bipartisan Budget Act of 2015 (BBA), which provide that for tax years beginning after December 31, 2017, all entities taxable as...more

Dickinson Wright

New IRS Audit Rules: Is Your Healthcare LLC Ready?

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The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

Kilpatrick Townsend & Stockton LLP

Comprehensive Partnership Audit Reform Requires Amendments To Partnership (and LLC Operating) Agreements

Congress has recently scrapped the existing procedures for IRS audits of partnerships. The new rules (the “BBA Audit Rules”1) are effective for partnership taxable years beginning on or after January 1, 2018. A partnership...more

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