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Tax Liability TEFRA Audits

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Whitman Legal Solutions, LLC

If One Musician Plays A Wrong Note, the Entire Orchestra Now May Pay the Price -- Be Aware of New Partnership Tax Audit Rules

In 1985, the “participatory journalist” George Plimpton worked as a temporary percussionist, playing sleigh bells, triangle, bass drum, and most notably, gong, with the New York Philharmonic. During a performance, he once...more

Butler Snow LLP

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

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The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

Lowndes

Five Things You Need to Know Now About the New Partnership Audit Rules

Lowndes on

Currently, most federal income tax audits of partnerships are governed by TEFRA, the Tax Equity and Fiscal Responsibility Act of 1982. In the simplest terms, TEFRA provides for a partnership audit to be conducted at the...more

Allen Matkins

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

Allen Matkins on

One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...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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