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Tax Law Roundup current law developments in U.S. taxation

Tag Archives: audit

Congress Passes Partnership Audit Reform – Obama Expected to Sign

Posted in General, Legislative, Partnership/LLC, Passthrough Entity, Procedure

This morning the Senate passed H.R. 1314 (The Bipartisan Budget Act of 2015), which will completely change the way partnerships (and LLCs taxed as partnerships) are audited.  The House passed the legislation on Wednesday and it is reported that President Obama will sign the legislation as soon as it reaches his desk.  As discussed in… Continue Reading

New IRS Guidance to Field on Applying Economic Substance Doctrine

Posted in Economic Substance, Tax Shelters

The IRS issued guidance to its field offices to instruct examiners when appropriate to seek approval to raise the economic substance doctrine.  The guidance also sets forth a series of inquiries the examiner must develop and analyze in order to seek approval for the ultimate application of the doctrine in the examination. Substantive guidance includes… Continue Reading