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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 not...

Business Tax Overhaul Obstacles

By Amanda Wilson on Feb 9, 2016 in Business Owners, Congress, government, medical marijuana, Obama care, S Corporation, Tax

There was an interesting article in yesterday's Wall Street Journal about the difficulties facing an overhaul of the tax system. The article can be found here.

FIRPTA Withholding Tax Set to Increase

By Amanda Wilson on Feb 8, 2016 in Other, Real estate, path act, Tax

By: Amanda Wilson The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in companies that predominately hold real estate....