Ideas & Insights

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

LB&I’s compliance campaign focuses on taxpayer reporting of purchase price allocations in taxable asset acquisitions.

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.

In lieu of an in depth analysis, partnerships may utilize one of three ‘snapshot’ methods to comply with tax capital reporting requirements.

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.

In a request for comments, the service outlines potential calculation methods – but also suggests disallowing an extremely common method.

The ability to revoke elections and file amended returns means partnership may have more than one option to benefit from CARES Act.

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

Rate reduction triggered after revenue metrics achieved; draft TCJA guidance published addressing the personal income tax.

Tax Court holds records and testimony by taxpayer were sufficient to support their claim that rental activities were non-passive.

A critical analysis of the government’s proposed regulations for the 20 percent deduction, with recommendations for possible improvement.

The Tax Court expressed skepticism regarding the substance of “paper entities” formed to generate a tax benefit that didn’t exist previously

The IRS issued final regulations on the designation and authority of the partnership representative under the new partnership audit regime.

Burden-shifting rule for individuals requiring the government to prove the validity of penalties in litigation does not reach partnerships.

Final IRS regulations limit the ability of many partnerships to avoid the new centralized partnership audit regime rules.