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The 20 Percent Deduction for Pass Through Income

The tax bill presented for the President's signature contains the 20 Percent Deduction for pass through income for the majority of US partnerships, S Corporations and sole proprietorships.  Under existing tax law, business profits were passed through to the individual and taxed at their personal income rate.  The top individual...

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...

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...