Second Quarter Newsletter 2018

The omnibus appropriations bill signed into law on March 23, 2018 included several technical corrections to the new partnership audit regime (the “Technical Corrections”), originally enacted in 2015, that goes into effect for partnership taxable years beginning in 2018. Many of the Technical Corrections were included in a technical corrections bill proposed in 2016 but never enacted. Other changes echo proposed regulations promulgated in 2017, giving legislative authority to those rules. Key among the Technical Corrections are authorization to use a push-out procedure in tiered partnerships, a new “pull-in” procedure, and rules governing partnerships that do not pay assessments following an audit. Note that the omnibus bill generally did not include technical corrections relating to the tax reform legislation enacted in December 2017 (with one exception to address the so-called “grain glitch”).
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In this Ropes & Gray podcast, Gabby Hirz, counsel in the tax controversy group, is joined by Loretta Richard, a partner in the tax and benefits group and co-founder of the tax controversy group, and Christi Lazo, counsel in the private client group, to discuss another notable Tax Court decision, Lender Management LLC v.

In a recent Tax Notes International article, “Is Fishing in Tax Waters Getting Easier or Just More High Tech?,” Brian Studniberg, Gabby Hirz and Loretta Richard provide commentary on the continued role of international information exchange on request given the availability of automatic information exchange.

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In a recent Tax Notes article, “Essential Guidance in the TCJA’s Wake,” Kat Gregor highlights key areas of focus for the U.S. Treasury when drafting guidance following the passing of the Tax Cuts and Jobs Act. Kat notes that the top priority should be provisions affecting 2017 tax liabilities, which include the new withholding obligation

On February 27, 2018, the Boston Chapter of the Federal Bar Association (FBA) Tax Section and Ropes and Gray co-hosted an event that featured Judge David Gustafson of the United States Tax Court. The event provided the opportunity for attendees to network and connect with other practitioners from Boston area law and accounting firms, the

On March 13, 2018, the IRS announced its first substantive Large Business and International Division (“LB&I”) compliance campaigns focused on partnerships and their partners. Although in January 2017, the IRS announced its intent to conduct a “TEFRA Linkage Plan Strategy Campaign” geared toward new procedures and techniques for assessing tax on partners after TEFRA-audits, its

On March 13, 2018, the IRS announced a new Large Business and International Division (“LB&I”) compliance campaign determined to impose tax adjustments on taxpayers who have deducted the costs associated with a tax-free spin-off, split-off or split-up under Section 355. In general, transaction costs to facilitate section 355 transactions must be capitalized. The IRS will

In this Ropes & Gray webinar, tax partners Kat Gregor and Jim Brown and moderator Kathryn Seevers discuss the trilogy of proposed partnership audit regulations that provide rules implementing many aspects of the provisions of the Bipartisan Budget Act of 2015. The most notable set of regulations allows for “push-out” elections to be effective in