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...

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...

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...

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Amanda Wilson As previously discussed (here), TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.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