Posts from October 2016.
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)...
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...
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...
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...

A New Era of Partnership Representation Before the IRS

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