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THE IMPACT OF THE NEW PARTNERSHIP AUDIT RULES ON INVESTMENT PARTNERSHIPS

Every LLC accountant should have at least a basic knowledge of the draconian new partnership audit rules in the Bipartisan Budget Act of 2015.  The new post under the link below addresses the impact of these investment partnerships.

Here is the link:  http://www.lexology.com/library/detail.aspx?g=1d2a521d-d225-4cfe-a58a-9d610bdb2101&l=7TAYUBB

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NEW HAMPSHIRE INCOME TAX

Income taxes have long been anathema in New Hampshire, but this may change. Below are the first two paragraphs in a Tax Analysts article about a New Hampshire bill proving for a new, broad-based flat-rate income tax. Amazingly, the bill has bipartisan support.

“A New Hampshire House bill would establish an individual income tax in the state and repeal or reduce several existing state taxes, including the business profits tax and the business enterprise tax.

H.B. 415, sponsored by Rep. Paul Henle (D), would establish a 3.95 percent flat rate tax on adjusted gross income. The tax is estimated to bring in $1.3 billion, according to the fiscal note in the bill.”

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POST ABOUT LLC ALLOCATIONS AND DISTRIBUTIONS

The attached post under the link below from Lou Vlahos of FarrellFritz addresses a recent Tax Court case involving the duty of members of entities taxable as partnerships (including most multi-member LLCs) to pay federal income taxes on allocations of LLC income to them even if their partnership make no distributions of cash to them to enable them to make these payments.

Here is the link:  http://www.taxlawforchb.com/2016/12/for-what-does-it-profit-a-man-to-save-his-partnership-yet-forfeit-his-ability-to-pay-his-taxes/

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REMINDER! SEMINAR ON NEW PARTNERSHIP AUDIT RULES

On January 23, 2017, I will be teaching a 1.5 CPE-credit seminar from noon to 1:30 PM at the Manchester Chamber of Commerce (54 Hanover Street) on how to advise LLC clients about the IRS’s draconian new partnership audit rules. Lunch will be supplied. For further information, please call me at (603) 856-7172. To enroll, please e-mail Amanda Nelson at anelson_law@yahoo.com.

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TREASURY FINAL REGULATIONS ADDRESSING USE OF US LLCS TO DISGUISE BENEFICIAL OWNERSHIP

The post under the link below concerns new Treasury final regulations addressing the use of U.S. single-member LLCs to disguise foreign beneficial ownership of the LLC and its assets.

Here is the link:  http://www.lexology.com/library/detail.aspx?g=1d2a521d-d225-4cfe-a58a-9d610bdb2101&l=7TAYUBB

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DISGUISED SALES

The concept of “disguised sales” is key in federal partnership taxation; it is thus key for most multi-member LLCs.  The blog post under the link below provides a brief but up-to-date and very clear explanation of the concept.

Here is the link:  http://www.taxlawforchb.com/2016/10/happy-halloween-partnership-disguised-sales-get-it/

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SEMINAR ON NEW PARTNERSHIP AUDIT RULES

On January 23, 2017, I will be teaching a 1.5 CPE-credit seminar from noon to 1:30 PM at the Manchester Chamber of Commerce (54 Hanover Street) on how to advise LLC clients about the IRS’s draconian new partnership audit rules. Lunch will be supplied. For further information, please call me at (603) 856-7172. To enroll, please e-mail Amanda Nelson at anelson_law@yahoo.com.

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THE NEW PARTNERSHIP AUDIT RULES

The new partnership audit rules under the Bipartisan Budget Act of 2015 are extremely problematical not only for large LLCs taxable as partnerships but also for small ones.  These rules radically need not just interpretative Treasury and IRS regulations and rulings but Congressional amendment.  A new bill for that purpose has been introduced.  The post under the link below provides an excellent summary of the bill.  Every LLC lawyer whose clients include LLCs taxable as partnerships should have at least a general awareness of the bill’s contents.

Here’s the link:  http://www.lexology.com/library/detail.aspx?g=8df43642-afda-47de-b72f-544c5e6313e6&l=7T9NXGH

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RESPONSIBILITY FOR FEDERAL EMPLOYMENT TAXES

The managers of LLCs, like those of other business entities, must make timely payment of federal payroll taxes owed in respect of their employees; if they don’t, they may face serious IRS consequences.  In the new post under the link below, Lou Vlahos of the FarrellFritz law firm discusses a recent Tax Court case concerning a corporate “responsible person” issue.  The principles underlying the case apply equally to LLCs.

Here’s the link:  http://www.taxlawforchb.com/2016/11/when-irresponsible-partners-are-responsible-persons/

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TAX ISSUES IN PURCHASES AND SALES OF BUSINESS ENTITIES

If your practice involves forming LLCs, I can guarantee you that before long, it will also involve assisting your LLC formation clients in buying and selling LLCs and other business entities.

The following post by Lou Vlahos of the FarrellFritz law firm contains an excellent summary of several key federal tax rules governing these sales and purchases.

http://www.taxlawforchb.com/2016/10/acquisitive-deals-capitalized-costs-and-termination-fees/

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