Last week, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations concerning the designation and authority of a partnership representative under the centralized partnership audit regime...more
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
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
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
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
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
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
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