
Tax Alert
IRS partially finalizes passthrough interest limitation regulations
Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.
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.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
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.
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.
The IRS issued final regulations on the designation and authority of the partnership representative under the new partnership audit regime.
Regulations provide rules governing contributions of property to a partnership having a foreign partner related to the contributing partner.
Michigan enacts amendments ending flow-through entity withholding for tax years beginning on or after July 1, 2016.
Arizona governor signs legislation conforming to federal partnership audit changes as enacted by the Bipartisan Budget Act of 2015.