News & Analysis as of

Audits U.S. Treasury Partnerships

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

Allen Barron, Inc. on

New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Perkins Coie

IRS to Target High Net Worth Individuals, Private Foundations, and Associated Entities Beginning in July 2020

Perkins Coie on

The Internal Revenue Service (IRS) intends to audit hundreds of high net worth individuals and their related entities starting this month. The campaign, announced at a conference by a top IRS division commissioner, will...more

McGuireWoods LLP

Time to Update Your Partnership Agreement: New Rules Address Partnership Representatives for IRS Audits

McGuireWoods LLP on

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

Bracewell LLP

Application of Partnership Audit Rules to Private Funds

Bracewell LLP on

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more

Dechert LLP

Newly Proposed Partnership Audit Rules Allow for Multiple-Tier “Push-Out” Election

Dechert LLP on

The U.S. Department of the Treasury (the “Treasury”) and the U.S. Internal Revenue Service (the “IRS”) have issued a new installment of proposed regulations under the centralized partnership audit regime included in the...more

Dechert LLP

Reissuance of Proposed Regulations on Partnership Audit Rules

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

Proskauer - Tax Talks

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

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

Locke Lord LLP

New Regulations for Partnerships Electing into New Partnership Audit Rules Early

Locke Lord LLP on

New partnership audit rules enacted into law on November 2, 2015 (the “New Partnership Audit Rules”) generally call for all determinations of adjustments to income and payments of tax pursuant to a partnership tax audit,...more

Katten Muchin Rosenman LLP

IRS Issues New Partnership Audit Procedures

Included as a revenue offset in the budget legislation (H.R. 1314) signed by President Obama are provisions that simplify the procedure for the Internal Revenue Service to audit and collect adjustments from partnerships. The...more

Morgan Lewis

New Legislation Makes Sweeping Changes Impacting All Partnerships

Morgan Lewis on

All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

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