News & Analysis as of

TEFRA

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

IRS Proposes Update and Streamlining of Public Approval Under TEFRA

by Miles & Stockbridge P.C. on

The Internal Revenue Service (the “IRS”) and The U.S. Department of the Treasury (the “Treasury”) proposed regulations on September 28, 2017 to update and streamline the public approval requirement applicable to tax-exempt...more

Proposed Treasury Regulations Bring the Public Notice Requirements into the 21st Century

by Bracewell LLP on

Recently released proposed regulations (the “Proposed Regulations”) relating to the public notice and approval requirements for private activity bonds (the “Public Approval Requirement”) – sometimes referred to as the TEFRA...more

IRS Releases New TEFRA Regulations

Last week, the IRS released proposed regulations (“Proposed Regulations”) relating to the so-called TEFRA public notice and approval requirement for private activity bonds. In general, the Proposed Regulations make it easier...more

IRS Proposed Regulations Make Registered Form Determination for Bonds More Bearable

On September 19, 2017, the Internal Revenue Service (IRS) issued proposed regulations providing helpful guidance on whether a debt instrument is in “bearer” or “registered” form. (REG-125374-16). While the paradigm debt...more

Time to Revise Your Partnership and LLC Agreements?

by Charles (Chuck) Rubin on

In June, the IRS reissued proposed regulations that adopt new centralized partnership audit procedures. These will replace the current TEFRA audit rules. The short story is that by default, the PARTNERSHIP is responsible...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

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

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

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

Holding the Bag: Update Your Operating Agreement or Face the Tax Consequences

by Partridge Snow & Hahn LLP on

New Law – Direct Assessment of LLC Tax Liability - The Tax Equity and Fiscal Responsibility Act (“TEFRA”) has governed the procedures for auditing partnerships since 1982. Under TEFRA, if the IRS audited an LLC taxed as a...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

July 2017 Federal Tax Alert – New Partnership Audit Regulations

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) recently reissued 277 pages of proposed regulations and a preamble (REG-136118-15) regarding the new centralized partnership audit rules enacted as part of...more

Reissuance of Proposed Regulations on Partnership Audit Rules

by Dechert LLP on

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

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

by Morrison & Foerster LLP on

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

by Proskauer - Tax Talks on

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit...more

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

by Butler Snow LLP on

The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

Introduction to Tax For Public Finance – Tax Presentation

Introduction to Tax for Public Finance - • What is the tax-exemption for state and local bonds? • Types of tax-exempt bonds • Overview of federal income tax requirements... Please see full Publication...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

by Ropes & Gray LLP on

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

2017 Annual Update – Bryan Cave Private Funds Practice

by Bryan Cave on

As we move into a new year, we have taken the opportunity to prepare an Annual Update for our investment adviser and private fund clients. This Annual Update reflects on major statutory and regulatory changes from 2016,...more

Treasury Releases Proposed Rules Implementing Partnership Audit Regime; Awaiting Publication in the Federal Register

by Ropes & Gray LLP on

On January 18, 2017, the Department of Treasury (“Treasury”) released proposed regulations (REG-136118-15) (the “Proposed Regulations”) implementing the partnership audit provisions of the Bipartisan Budget Act of 2015 (the...more

First LB&I Campaigns Demonstrate a Flexible Approach

On January 31, 2017, the Large Business & International Division of the IRS (LB&I) released the subjects of its first 13 campaigns. Each campaign addresses a specific area that the IRS has identified as a substantial...more

IRS Issues Proposed Regulations on Centralized Partnership Audit Regime

On January 18, 2017, the IRS released proposed regulations (the "Proposed Regulations") to implement Section 1101 of the Bipartisan Budget Act of 2015 (BBA),1 which replaces the current rules governing partnership...more

California Debt Limit Allocation Committee Releases Proposed Regulations

This client alert discusses some of the more significant changes that could affect issuers and borrowers in connection with awards of volume cap if the proposed regulations were adopted in their current form. The...more

MoFo Tax Talk - Volume 9, No. 3

by Morrison & Foerster LLP on

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

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