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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...

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...

New IRS Guideline Requires Partnerships and LLCs to Name Representative for IRS Audits

New legislation has been enacted that will require partnerships and LLCs to name a partnership representative for IRS Audits.  The new laws (which go into effect in several months) affect existing partnerships and LLCs, as well as any newly created LLC or partnership agreements, private placement memoranda, or any contract...