Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their

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Chief Counsel on What Makes Amounts Paid To “Limited Partners” of an LLC Subject To Self-Employment Taxes

IRS Chief Counsel (CCA 201436049) has concluded that so-called limited partners of an investment management firm were not limited partners of the firm (a limited liability company (LLC) treated as a partnership) and were being paid compensation for services. Therefore, the amounts they received from the firm

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Health Care Tax Tip for The Individual Shared Responsibility Payment (Affordable Care Act)

The Individual Shared Responsibility Payment Beginning in 2014, the individual shared responsibility provision of the Affordable Care Act requires each individual to: Maintain a minimum level of health care coverage – known as minimum essential coverage , or Qualify for an exemption , or Make an individual

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IRS’ Overhaul of Streamline & Offshore Voluntary Disclosure Program “OVDP”

On June 18, 2014, the IRS announced comprehensive changes to both the Streamlined and the Offshore Voluntary Disclosure Program (“OVDP”) programs. Such changes to the Streamline Program include: Streamlined Program 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States 2.

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IRS Funding Cuts May Lead to Reductions In IRS Services

Commissioner John Koskinen recently cautioned taxpayers they should expect more reductions in IRS services because of budget cuts.  Koskinen’s warning comes as the IRS prepares for year-end tax legislation as well as implementing its voluntary return preparer education program and combatting tax-related identity theft. According to Fred

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