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Goodbye TEFRA, Hello New Partnership Audit Rules

By Amanda Wilson on Nov 9, 2015 in audit, government, International, IRS, Partnership Tax, Tax

By:  Amanda Wilson Last week, President Obama signed into law the Bipartisan Budget Act of 2015.  As I mentioned in a prior post (found here), the budget bill contained a proposal to revamp how partnerships are audited.  Specifically, TEFRA (the...

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,...

Status Update on Targeted Allocation Regulations

By Amanda Wilson on Sep 18, 2015 in Other, code, International, IRS, targeted allocations, Tax

By: Amanda Wilson I'm at the ABA Tax conference this week and one of this morning's first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries, discussed the...