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23, 2018 included several technical corrections to the new partnership audit regime (the “Technical Corrections”), originally enacted in 2015, that goes into effect for partnership taxable years beginning in 2018.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 a recent Tax Notes International article, “Is Fishing in Tax Waters Getting Easier or Just More High Tech?,” tax & benefits associate Brian Studniberg, former tax controversy counsel Gabby Hirz and tax controversy group co-founder and employee benefits partner Loretta Richard provide commentary on the continued role of international information exchange on request given

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

In a recent Bloomberg article, “IRS Cops Are Scouring Crypto Accounts to Build Tax Evasion Cases,” tax attorney Jim Brown commented on the IRS’ interest in investigating taxpayers who have crypto accounts or have made unlicensed exchanges in the U.S. and overseas. Jim noted his investor clients “believe that effective regulation and law enforcement would