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Pass-Through Entities Internal Revenue Service Partnerships

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

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In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...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

Foodman CPAs & Advisors

Inteligencia Artificial Asiste Al IRS Con Los Evasores De Impuestos

El 20/09/23, el IRS anunció que planea establecer un área especial para centrarse en entidades de transferencia grandes o complejas para ayudar con los esfuerzos de cumplimiento de altos ingresos. Con la ayuda de tecnología...more

Foodman CPAs & Advisors

Artificial Intelligence To Assist IRS With Tax Cheats

On 9/20/23, the IRS announced that it plans to establish a special area to focus on large or complex pass-through entities to help with high-income compliance efforts. With the assistance of improved technology as well as...more

Vinson & Elkins LLP

The Heat Is on for Large Partnership Audits

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Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more

McDermott Will & Emery

IRS Strengthens Its Large Partnership Audit Teams

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Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

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I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act targets carried interests

On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

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Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Miles & Stockbridge P.C.

And Then There Were Some: Maryland, Virginia, and DC’s Stance on Pass-Through SALT Deduction Workarounds

In late 2020, the IRS issued a notice confirming imminent proposed regulations that would allow certain tax strategies to avoid the individual $10,000 state and local tax (“SALT”) deduction limitation of the Tax Cuts and Jobs...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

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Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

McDermott Will & Emery

Weekly IRS Roundup December 6 – December 10, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 6, 2021 – December 10, 2021... December 6, 2021: The IRS published updated guidance on...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...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

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

McDermott Will & Emery

Illinois Enacts Pass-Through Entity Tax to Help Partners and S Corporation Shareholders Avoid the $10,000 SALT Cap

Illinois enacted a pass-through entity tax (PTE Tax) that may be elected by partnerships and S corporations to permit a federal deduction of state income taxes that otherwise are limited to $10,000 per year from 2018 to 2025...more

Bradley Arant Boult Cummings LLP

The MTC Undertakes an Ambitious Study of Partnership Taxation

On April 27, 2021, the Multistate Tax Commission (MTC) Uniformity Committee voted to accept its Standing Subcommittee’s recommendation to create a work group to study several key issues relating to multistate taxation of...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Rivkin Radler LLP

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

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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

White and Williams LLP

IRS to Allow “Workaround” to Deduction Limits for State and Local Income Taxes

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The Tax Cuts and Jobs Act (2017 Tax Act) limited the deduction of state and local taxes to $10,000 for individuals. Several states, including Connecticut, New Jersey and Maryland, have passed legislation that imposed income...more

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