Goodbye TEFRA, Hello New Partnership Audit Rules

By: Amanda Wilson

Last week, President Obama signed into law the Bipartisan Budget Act of 2015.  As I mentioned in a prior post (found here), the budget bill contained a proposal to revamp how partnerships are audited.  Specifically, TEFRA (the 1982 Tax Equity and Fiscal Responsibility Act) is out.   The new partnership audit rules go into effect for partnership returns filed for partnership taxable years beginning after December 31, 2017. read more

Beware Transferee Liability

By:  Amanda Wilson

One of the great features of corporations is that liability in the corporation generally does not extend to its shareholders, including tax liability.  Like any rule, though, there is almost always an exception.   In this case, the exception can be brutal. read more

Worthless Debt Deduction – A Cautionary Tale

By:  Amanda Wilson

For partnership, individuals and other types of taxpayers that are not in the business of making loans, the main avenue for tax relief when a loan goes bad is Section 166 – the bad debt deduction.  In order to claim this deduction, the taxpayer must show that the debt has become wholly worthless during the tax year in which the deduction is claimed.  This can often be a very difficult burden for taxpayers, especially if there is no external event that they can identify as a trigger for worthlessness.  Even if there is such an event (such as the borrower declaring bankruptcy), worthlessness can be difficult to establish. read more