What are disregarded entities and how does this relate to an IRS FBAR? There is a lot about "disregarded entities" in the news recently due to a recent ruling by the IRS in conjunction with offshore asset and income reporting and FBAR requirements. A disregarded entity has been the IRS'...
New Tax Plan Presents Challenges for IRS Auditors
The new tax plan presents challenges for IRS auditors as we all await the final draft of tax reform legislation in Washington. The primary concern centers around the ability of wealthy US taxpayers to "reap massive windfalls" by simply reclassifying income as "pass-through business income." The most recent "final" plan...
Significant Changes to IRS Audit Procedures for Partnerships and LLCs
Significant changes to IRS audit procedures for partnerships and LLCs will go into effect January 1, 2018. The changes will apply to all partnerships and LLCs who elect to be taxed as partnerships. The change is represents a substantial change in methodology when amounts are owed to the IRS and...
Changes to Partnerships and LLCs Required by IRS
There are substantial changes to partnerships and LLCs required by the IRS as part of the Bipartisan Budget Act (BBA) which are scheduled to take effect January 1, 2018. The US Treasury Department issued new rules in January of this year which will substantially impact tax matters for partnerships as...
IRS Large Business and International Division Targeting TEFRA Violations
The IRS Large Business and International Division (LB&I) will be targeting TEFRA violations in partnerships based upon recent changes in partnership related tax law. TEFRA (The Tax Equity and Fiscal Responsibility Act of 1982) regulations applying to partnerships created a set of consolidated IRS audit (examination), processing and judicial procedures which...