• In response to audit efficiency issues identified by the Internal Revenue Service (IRS), the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) contained provisions which allowed the IRS to conduct a single administrative proceeding (audit) at the partnership level, adjust the tax treatment of any partnership tax item and determine the applicability of any penalty or other addition to tax at the partnership level (rather than at the level of each of the partners)
  • The determination of the appropriate UOP is the first step in determining the need to capitalize an expenditure related to real property. Once the UOP is determined, the new improvement standards from the final regulations can be applied. Many real estate businesses will need to file an accounting method change (filing Form 3115) to adopt the new UOP rules as they apply to their buildings.
  • As a result of the economic downturn, the federal government has enacted a number of generous provisions in the tax law over the last several years that have been aimed at increasing investment in real property and otherwise improving the economy as a whole.
  • The requirement to report the ownership of foreign bank and financial accounts has been in place for many years, but until the recent UBS scandal it was treated more like a formality and was probably not given too much attention by practitioners who have
  • Section 1446 of the IRS Code requires a partnership that has foreign partners to withhold tax on income effectively connected with a U.S. trade or business.