Gianni, Partnership Audit Rules: After the Final Regulations

Assistant Professor Monica Gianni, California State University Northridge, has made available for download her article, Partnership Audit Rules: After the Final Regulations, published in the Journal of Taxation of Financial Products. The Abstract is as follows: As part of the Bipartisan Budget Act of 2015 (BBA), Congress repealed the TEFRA audit rules and the audit … Continue reading Gianni, Partnership Audit Rules: After the Final Regulations

TAM 201929019: Deemed Partnership Distribution Treated as Exchange

In TAM 201929019, the deemed distribution of a partnership interest in an assets-over merger of two partnerships was treated as a Code Sec. 761(e) "exchange," which required a mandatory Code Sec. 743(b) downward inside-basis adjustment when the resulting partnership had a substantial built-in loss. The issues presented and rulings made were as follows: Issues: 1. Is … Continue reading TAM 201929019: Deemed Partnership Distribution Treated as Exchange

CCA 201928014: Corporate Charitable Contribution Carryover Adjustment Determined Using NOL Absorption Computation

The IRS in CCA 201928014 ruled that a corporation with several years of NOL carryovers and charitable contribution carryovers must determine a charitable contribution carryover adjustment using a chronological, year-by-year NOL absorption computation. The IRS stated that using an aggregate basis standard to determine the adjustment was not accurate. The IRS also stated that the … Continue reading CCA 201928014: Corporate Charitable Contribution Carryover Adjustment Determined Using NOL Absorption Computation

Hales & Tingey, Sec. 1341: What is the claim-of-right doctrine?

Adam Hales, CPA, and Dennis Tingey, CPA, have published their article, Sec. 1341: What is the claim-of-right doctrine? in the AICPA Tax Adviser. The introduction is as follows: The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, enacted Dec. 22, 2017, made numerous changes to the U.S. tax rules affecting businesses and … Continue reading Hales & Tingey, Sec. 1341: What is the claim-of-right doctrine?

Proposed Regs: Passive foreign investment companies (PFICs) and PFIC insurance exception

The Treasury Department and IRS has released proposed regulations (REG-105474-18) regarding passive foreign investment companies (PFICs) and specifically concerning legislative changes made by the Tax Cuts and Jobs Act of 2017 with regard to the “PFIC insurance exception.” The Regs summary is as follows: This document contains proposed regulations under sections 1291, 1297, and 1298 … Continue reading Proposed Regs: Passive foreign investment companies (PFICs) and PFIC insurance exception