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 Amanda Wilson As previously discussed (here), TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.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

Treasury Cracking Down on Secret Real Estate Sales

By Amanda Wilson on Jan 14, 2016 in Real estate, International, irc, IRS, LLC, Tax, treasury

By:  Amanda Wilson There was an interesting story this morning on CBS about the Treasury Department cracking down on secret real estate sales.  Going forward, buyers and sellers may be limited in their ability to hide behind limited liability...