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New Partnership Audit Regs Final Before Year End?

By Amanda Wilson on Feb 23, 2016 in government, International, IRS, Partnership Tax, path act, Tax

By:  Amanda Wilson At a tax conference yesterday, a Treasury official indicated that Treasury is working hard to finalize regulations before the 60-day freeze that occurs before the inauguration of a new president (Treasury will not issue final...

Bad Boy Guarantee Makes Loan Recourse?

By Amanda Wilson on Feb 17, 2016 in International, IRS, Tax

By:  Amanda Wilson The IRS recently released IRS legal memorandum 201606027.  In this memorandum, the IRS considered the impact of a bad boy guarantee on allocating partnership liabilities under Section 752.  Traditionally, bad boy guarantees have...

Protect Yourself Against Tax Fraud

By Amanda Wilson on Feb 5, 2016 in identity theft, International, IRS, Tax

By:  Amanda Wilson I've written in the past about the huge amount to tax identity fraud that takes place, and some ways that you can protect yourself.  Today's Wall Street Journal has a great article with other suggestions that you can take.  The...

Electing into New Partnership Audit Rules

By Amanda Wilson on Feb 2, 2016 in audit, government, International, IRS, lowndes, Partnership Tax, treasury

By:  Amanda Wilson As previously discussed (here), TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.  The new audit rules...