What We Do

What We Do

Daily Tax Report Quotes Charles Ruchelman: IRS Revving Up Efforts to Find Partners Who Owe Tax
Daily Tax Report Quotes Charles Ruchelman: IRS Revving Up Efforts to Find Partners Who Owe Tax

The Internal Revenue Service is working to develop better ways to find the partners or other investors who owe tax—and represent the most risk—in immensely complex partnership structures. The agency said it will be focusing…

IRS Proposed Partnership Audit Rules Withdrawn from OFR
IRS Proposed Partnership Audit Rules Withdrawn from OFR

The IRS’ proposed partnership audit rules were withdrawn from The Office of the Federal Register following a government-wide executive order from President Donald Trump freezing all new and pending regulations, with some exceptions for health,…

IRS Publishes Proposed Partnership Audit Rules
IRS Publishes Proposed Partnership Audit Rules

On January 19, 2017, the IRS published proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA)…

Fixes For Partnership Audit Regime Likely Pushed to 2017
Fixes For Partnership Audit Regime Likely Pushed to 2017

Technical corrections to the new regime for auditing partnerships aren’t likely to happen this year, as Congress is looking to wrap up 2016 quickly with a short-term spending bill and little else…

IRS Chief Skeptical of New Audit Regime for Partnerships
IRS Chief Skeptical of New Audit Regime for Partnerships

A law intended to make it simpler for the Internal Revenue Service to audit partnerships may turn out to be problematic for the agency to administer, the IRS chief said. Commissioner John Koskinen said it’s possible that taxpayers and the agency might be worse off under the new system because “nobody quite asked, ‘Hey, would this really work?’” before the legislation was passed…

New Regulations Change Allocation of Partnership Liabilities
New Regulations Change Allocation of Partnership Liabilities

On October 4, 2016, the Treasury Department and Internal Revenue Service (IRS) issued revised regulations governing how recourse partnership liabilities are allocated among partners. These temporary regulations, which are binding on taxpayers immediately, relate to so-called “bottom-dollar payment obligations” (BDPOs)…

New Partnership Audit Regime: Did You Know…
AICPA Offers Comments/Recommendations to New Partnership Audit Regime
AICPA Offers Comments/Recommendations to New Partnership Audit Regime

The AICPA recently released comments and recommendations in response to Notice 2016-23, Request for Comments Regarding Implementation of the New Partnership Audit Regime Enacted as Part of the Bipartisan Budget Act of 2015, issued on March 4, 2016. Visit this link for the expanded version. Below is an outline of the AICPA comments and recommendations…

Bloomberg Quotes Charles Ruchelman: Partnerships Up a Creek Without a Pushout in JCT Analysis
Bloomberg Quotes Charles Ruchelman: Partnerships Up a Creek Without a Pushout in JCT Analysis

Caplin & Drysdale’s Charles M. Ruchelman spoke with Bloomberg BNA’s Laura Davison regarding the potential for investment in partnerships declining and S corporation status gaining in popularity if neither Congress nor the IRS revise a disputed provision in the new partnership audit regime about how far a multitiered entity can push out an adjustment…

IRS Writing Partnership Audit Guidance Based on Present Law
IRS Writing Partnership Audit Guidance Based on Present Law

The Internal Revenue Service is moving forward with regulatory guidance on the new partnership audit and tax collection regime as it was enacted last year, even as controversy continues in Congress and among practitioners about whether technical corrections are necessary, an IRS official said on September 30, 2016…