Repeal of TEFRA: Planning for Changes to IRS Partnership Audits
In November 2015 Congress passed the Protecting American from Tax Hikes Act of 2015 also known as the 2015 Bipartisan Budget Act (commonly referred to either as PATH 2015 or BBA) repealing the current procedure for partnership audits. Rules and … Continue reading
Fourth Circuit Affirms Tax Court re Allocation of State Credits
The Fourth Circuit recently confirmed another Tax Court decision finding that the allocation of state tax credits should be treated as a disguised sale for federal income tax purposes. Route 231, LLC v. Comm’r.[1] The result was unsurprising given the … Continue reading