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New Partnership Audit Rules Heading Our Way??

By Amanda Wilson on Oct 28, 2015 in audit, government, International, IRS, Partnership Tax, Tax

By: Amanda Wilson The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited. Specifically, it would repeal the much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules. The overall...

Beware Transferee Liability

By Amanda Wilson on Oct 15, 2015 in International, irc, IRS, medical marijuana, S Corporation, Tax, transferee

By: Amanda Wilson One of the great features of corporations is that liability in the corporation generally does not extend to its shareholders, including tax liability. Like any rule, though, there is almost always an exception. In this case, the...

Worthless Debt Deduction - A Cautionary Tale

By Amanda Wilson on Oct 7, 2015 in Other, International, IRS, tax court, tax return

By: Amanda Wilson For partnership, individuals and other types of taxpayers that are not in the business of making loans, the main avenue for tax relief when a loan goes bad is Section 166 - the bad debt deduction. In order to claim this deduction,...

IRS Finalizes Regs on F Reorgs

By Amanda Wilson on Sep 24, 2015 in Other, International, irc, IRS

By: Amanda Wilson The IRS has finalized its regulations on Section 368(a)(1)(F) reorganizations. An F reorganization is characterized as a mere change in the identity, form, or place of organization of one corporation. The final regulations provide...