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We Stay Up-To-Date on Flow-Through Tax News and Precedents So You Don't Have To.

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Gift or No Gift? A Tax Court Case Worth Considering

03/25/2025
News

We’re guessing that many of our readers are fully ensconced in Tax Season #1 and might welcome some “light reading” to take their minds off the tasks at hand. With that in mind, we’d like to share our take on a recent interesting Tax Court case that came to our attention.

02/11/2025
News

On January 31, 2025, the IRS Office of Chief Counsel released CCA 202505027 invalidating an agreement to extend the statute of limitations where an individual who signed the extension was different than the individual designated as the Partnership Representative (“PR”) on the Form 1065 filed with IRS (or the Designated Individual (“DI”) if an entity is the PR). Generally, the statute of limitations is three years from the date the return is filed or its original due date, whichever comes later. (§6235(a).) Code §6235(b) allows a taxpayer to extend the statute of limitations by agreement with the IRS, and if the taxpayer is a partnership subject to the BBA, Form 872-M, BBA Consent to Extend Time for Making Adjustments to Partnership-Related Items, is used to extend the statute to a specified date agreed to by the IRS and the partnership.

01/13/2025
News

On January 10, 2025, Treasury issued final regulations under Reg. §1.6011-18 classifying related-party basis adjustments as reportable transactions of interest (“TOIs”). The final regulations adopted, with modifications, the proposed regulations that were issued on June 18, 2024. The issues and rules specific to Notice 2024-54 (which accompanied the proposed regulations) are not addressed in the final regulations, but still are under consideration by Treasury and the IRS. See our June 20, 2024, email blast for more information regarding the proposed regulations, Notice 2024-54, and Rev. Rul. 2024-24.

12/17/2024
News

A partnership is required to attach a separate Form 8308 to its Form 1065, U.S. Return of Partnership Income, to report each sale or exchange of all, or a portion of, a partnership interest where there has been a “§751(a) exchange.”

12/10/2024
News

After 11 years, Treasury issued final regulations under §752 on November 29, 2024. (See TD 10014.) The final regulations follow the proposed regulations, with clarifications. Among other elucidations, the final regulations clarify the circumstances and degree to which a partner is treated as assuming the economic risk of loss for a partnership liability, especially in instances involving multiple partners sharing this risk.

11/18/2024
News

First, we at TAX FORUMS wish you a happy and healthy Thanksgiving and holiday season.

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None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.