AICPA Recommends Changes to Regulations on Assumption of Partnership Liabilities
Comment Letter:
This letter and comments concern proposed and temporary regulations regarding the assumption of partner liabilities under Section 752.
Published on June 06, 2013
AICPA Suggests a Partnership Sale or Exchange Reporting Requirement Simplification
Article:
The AICPA has made recommendations to both the IRS and Congress for changes to the process of reporting gains or losses on the sale or exchange of a partnership interest.
Published on May 02, 2013
Industry Resolution Program Issue 2008-110 Comment Letter - Tax Issues Related to Technical Terminations of Publicly Tra...
Comment Letter:
Technical terminations of a partnership occur fairly frequently. When they do, revaluations of partnership property, depreciation reset, 754 book-ups and a whole host of tax consequences must be addressed. In the context of a publicly-traded partnership with sometimes thousands of partners and potentially multiple terminations throughout the year, the problems
Published on May 01, 2013
Partnerships
Checklist:
This section contains AICPA comments and recommendations related to partnerships.
Published on April 23, 2013
AICPA Asks Congress for Relief From SILO Regs for Partnerships
Article:
In a letter to Congress, AICPA requests immediate relief under SILO legislation, because partnerships that have tax-exempt (including foreign) partners are unsure whether losses should be reported as suspended or disallowed in the situation where the partnership did not engage in any SILO or other leasing transactions.
Published on April 18, 2013
AICPA Requests Penalty Relief For Late-Filed Short Year Return After Partnership Technical Termination
Comment Letter:
Penalties of $195 per partner per month can be imposed on a partnership if they don't file a short year Form 1065 by the 15th day of the 4th month after a short year end created by a technical termination of a partnership under section 708(b)(1)(B). This very practical request
Published on March 28, 2013
AICPA Comments on Proposed Regulations Addressing Noncompensatory Partnership Options - January 22, 2003
Comment Letter:
AICPA believes the approach of the proposed regulations generally provide reasonable framework for taxing the issuance & exercise of noncompensatory partnership options but certain aspects require further clarification, illustration, or consideration.
Published on February 05, 2013
AICPA Asks IRS to Apply Anti-Mixing Bowl Changes Prospectively Only
Comment Letter:
AICPA offers comments to the IRS and Department of Treasury on Revenue Ruling 2004-43, which specifically addresses the application of sections 704(c)(1)(B) and 737 to the distribution of property by a partnership following an assets-over partnership merger.
Published on September 23, 2012
AICPA Recommends Clarifications to Noncompensatory Partnership Option Regs
Comment Letter:
The Internal Revenue Service and the Treasury Department issued proposed regulations which provide guidance on the issuance and exercise of partnership-issued non-compensatory options and convertible instruments.
Published on March 12, 2012
AICPA Comments on Proposed Regulations Relating to the Application of Section 108(e) to Partnerships and Their Partners ...
Comment Letter:
When a distressed partnership satisfies a debt by giving the creditor a partnership interest, the tax consequences, under these proposed regulations, may not be as you would expect in certain situations. In these comments, the AICPA has asked Treasury and IRS to reconsider some of their preliminary conclusions and to
Published on March 12, 2012
The AICPA Testifies Before the House Small Business Committee on Ways to Modernize the Tax Code
Comment Letter:
On April 10, 2008, in testimony before the US House of Representatives' Small Business Committee, the AICPA proposed changes to the taxation of S corporations, partnerships, the AMT, and estates.
Published on March 12, 2012
AICPA Written Testimony on Modernizing the Tax Code How Updating the Code Can Better Serve Small Business - April 10, 20...
Testimony:
AICPA proposed changes to the taxation of S corporations, partnerships, the AMT, and estates and lends support to pending bills on fiscal year flexibility, cell phones, and preparer penalties. The provided text includes a variety of other actions taken.
Published on March 12, 2012
AICPA Oral Testimony on Modernizing the Tax Code How Updating the Code Can Better Serve Small Business - April 10, 2008
Testimony:
AICPA proposed changes to the taxation of S corporations, partnerships, the AMT, and estates and lends support to pending bills on fiscal year flexibility, cell phones, and preparer penalties. The provided text includes a variety of other actions taken.
Published on March 12, 2012
Comments on Industry Resolution Program Issue 2008-110 Regarding Tax Issues Related to Technical Terminations of Publicl...
Comment Letter:
Technical terminations of a partnership occur fairly frequently. When they do, revaluations of partnership property, depreciation reset, 754 book-ups and a whole host of tax consequences must be addressed. In the context of a publicly-traded partnership with sometimes thousands of partners and potentially multiple terminations throughout the year, the problems
Published on March 12, 2012
AICPA Again Urges Congress to Grant Permanent Sale In Lease Out (SILO) for Some Partnerships
Comment Letter:
In this July 26, 2006, letter, the AICPA asks Congress to grant permanent relief from legislation designed to stop sale-in-lease-out transactions for partnerships with tax-exempt partners and nonqualified allocations.
Published on March 01, 2012