IRS releases Rev. Procs. 2021-48, 2021-49 and 2021-50 to address the treatment of tax-exempt income for PPP loans.
IRS releases Rev. Procs. 2021-48, 2021-49 and 2021-50 to address the treatment of tax-exempt income for PPP loans.
The Tax Court ruled that a loan used to fund the acquisition of the Chicago Cubs was akin to equity, yielding tax liability for the seller.
Sec. 108(e)(6), which can mitigate CODI, is not available to partnership debtors, and may not be available to some insolvent corporations.
Proposed Excess Business Loss limits could hurt real estate pro’s, others with active losses, including cash losses.
With tax software platforms, private equity funds have the real-time insights they need for smarter investment decision-making.
President Biden and Congress have proposed to increase the capital gains tax rate. Taxpayers may wish to create a taxable event.
Partnerships and corporations they control may trigger unexpected tax liabilities by transferring value from one to pay costs of the other.
House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.
Senator Wyden’s recent ‘discussion draft’ legislation, if enacted, would drastically alter many of the tax rules that apply to partnerships.
New guidance and dedicated website provide instruction to taxpayers electing into the pass-through entity tax workaround.
A look at allocation platform software and tiering technology platform software comparison: PartnerSight vs. the others
The entity-level tax election is effective for tax years beginning on or after Jan. 1, 2021 and ending before Jan. 1, 2026.
Private equity firms must be prepared to use tax data throughout the life cycle of the deal and respond to changing regulations.
Partnerships making certain narrow, and specified changes, may not need to file administrative adjustment requests.
Ninth Circuit reverses Tax Court, based on Congress’ provision of tax benefits based on form rather than substance.
RSM US LLP real estate professionals discuss the future of tax and technology automation, and how it can help real estate firms.
Allocation and tiering leader PartnerSight addresses challenges of getting private equity data tax-ready, helping ﬁnance teams drive value.
Investment partnerships face a complex landscape when it comes to tax compliance. The solution lies in partnership tax technology.
Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.
Devaluation caused by the pandemic may turn your company into a PFIC. However, there may be ways to mitigate tax costs.
Tax technology tools are always changing. Innovation can’t outpace you if you’re prepared with the right data and the right team.
LB&I’s compliance campaign focuses on taxpayer reporting of purchase price allocations in taxable asset acquisitions.
IRS modifies guidance on wages that are includible when computing section 199A deduction for taxpayers with short tax years.
In this short video, we bring you up to date on the final carried interest regulations and give guidance on actions fund managers may take.
Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.
New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.
Revenue procedure allows treatment of qualified residential living facility operations as a section 163(j) real property trade or business.
In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.
IRS addresses QSubs and period of limitations in a new set of proposed rules to the centralized partnership audit regime.
In lieu of an in depth analysis, partnerships may utilize one of three ‘snapshot’ methods to comply with tax capital reporting requirements.
IRS to focus on taxpayer compliance with the documentation requirement to allocate and deduct success-based fees.
This webcast will discuss carried interest regulations and what the proposed rules mean for investment fund managers.
This Alert summarizes impacts of the recently-issued interest deduction limitation guidance on the real estate industry.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
Proposed carried interest regulations are mostly as expected with a few new items and detailed computational rules.
Recent memo provides IRS view that certain stockless contributions create a split holding period on the stock.
Final regulations generally taxpayer-favorable versus 2018 proposal, additional proposed regulations give guidance on pass-throughs, others.
Volatility and uncertainty in the markets create an unprecedented opportunity to transfer carried interests at low tax cost.
Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.
In a request for comments, the service outlines potential calculation methods – but also suggests disallowing an extremely common method.
Finalized section 385 debt-equity regulations proposed in 2016, government still plans to issue some less harsh rules in the future.
The ability to revoke elections and file amended returns means partnership may have more than one option to benefit from CARES Act.
Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.
Recent guidance provides that certain deadlines, including the allowable time to invest in a QOF, are now extended because of COVID-19.
Notice 2020-23 clarifies that most filing, payment and election obligations for S corporations and partnerships is postponed until July 15.
Motivated by the tax relief provisions of the CARES Act, the IRS is allowing all partnerships to file 2018 and 2019 amended returns.
CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships
Proper tax planning in a workout or restructuring is necessary to provide valuable tax attributes to the restructured business.
Advisor must document amounts used to “investigate” an actual buy or sell – a study may make sense if amounts are substantial.
Redesigned forms and instructions require partnerships to reconsider tax basis capital and section 704(c) compliance processes.
IRS has issued final regulations narrowing nonrecognition treatment for certain transfers of property to partnerships with foreign partners.
Ruling expresses IRS’ views in areas where regulations are silent; reinforces the need for transaction cost analysis.
Delay in required reporting of tax basis capital may be less beneficial than it appears; many will still need to compute for 2019.
The IRS finalized Forms 8985 and 8986, a mechanism for partnerships to push-out partnership audit and AAR adjustments to their partners.
IRS to retain regulations treating some related party debt as equity, but will propose rules easing one of the regulations’ harshest rules.
Guidance would facilitate transitions of existing debt and derivatives to alternative benchmark rates without creating taxable exchanges.
Technology can help drive efficiencies for tax departments and help achieve strategic goals. Learn where you stand.
Target company’s deduction claim denied because investment banking firm did not provide services to Target or for Target’s benefit.
There are numerous ways that an S corporation can compromise its status. Being careless with election forms is just one example.
The IRS has finalized rules for bottom-dollar guarantees under the disguised sale rules and for partnership liability allocations generally.
Recently released draft 2019 Schedule K-1s showcase a major shift in reporting that may begin with the next filing season.
IRS has finalized safe harbor provisions that rental real estate enterprises may use to qualify as a trade or business for section 199A.
Final bonus depreciation rules similar to previously proposed rules, uncertainty remains for certain transactions.
Tax Court allows ordinary business bad debt deduction, rejecting argument that loans not secured by real property were nonbusiness loans.
Proposed regulations would accelerate credit card fee income and similar items, but would not affect most interest income items.
Actual extension not required to supersede timely filed return, avoiding new adjustment procedures, by extended return deadline.
Final regulations maintain partners cannot be employees of a disregarded entity owned by the partnership in which they are partners.
Tax Court found that the taxpayers established material participation despite failing other quantitative material participation tests.
Eleventh Circuit affirms Tax Court’s ruling that an S corporation shareholder will not get basis for amounts advanced by related entities.
The TCJA revised the long-standing prohibition on a nonresident alien being a potential current beneficiary of an ESBT
Proposed Sec. 465 regulations provide significant guidance and detailed examples of the application of the at-risk rules for partnerships.
A District Court’s refusal to dismiss case involving an election to, “close the books,” highlights importance of addressing issue up front.
Proposed regulations for section 250 deductions provide multi-step process to account for NOL deductions and interest deduction limitation.
Master service and related agreements raise ownership questions as well as question as to qualification under secs. 199A and 1202.
Under the Bluebook’s interpretation, intent for application of 80 percent limitation was taxpayer favorable.
The IRS has released the final pass-through deduction regs. This is welcome guidance to taxpayers claiming this new 20 percent deduction.
Published notice, describing intent to propose regulations, describes items that could be examined outside of a full partnership proceeding.
Revenue Procedure 2019-12 provides a safe harbor for businesses to deduct quid pro quo contributions under section 162.
While some items are still outstanding, the bulk of the guidance for partnership examinations of years 2018 and forward is now in place.
Proposed rules address many open issues and would prescribe complex calculations for taxpayers deducting business interest expense.
The IRS issued long-awaited guidance on the treatment of negative amounts subject to capitalization under the simplified UNICAP methods.
California conforms to the federal audit reporting rules for partnerships, and the Franchise Tax Board provides tax payment confirmations.
Fiscal year pass-through owners may claim DPAD on 2018 return despite repeal for fiscal years beginning after 2017.
A recent IRS private letter ruling highlights the need for caution when LLCs elect to be treated as S corporations.
The IRS, in a recent PLR, has allowed a taxpayer to change its entity classification election inside the general 60-month no change period.
Treasury official states income from an SSTB exceeding the de minimis threshold would bar a taxpayer from taking the 199A deduction.
Real Estate Roundtable’s Tax Policy Advisory Committee suggests liberalizations and clarifications to proposed regulations.
H.R. 6756, the American Innovation Act of 2018, increases the amount of start-up and organizational expenses a business can deduct.
PartnerSight is a cloud-based platform that delivers tax data in real time, providing powerful insights to make better investment decisions.
Find out how to unlock your data to maximize the value of your tax compliance function, plus hear answers to frequently asked questions.