Resources Archive
January 23, 2019
Thoughts and Consideration Regarding the Designation of a Partnership Representative...
[ read ]
In November 2015, as part of the Bipartisan Budget Act (BBA) of 2015, Congress enacted a new centralized partnership audit regime to replace the TEFRA partnership rules. The new centralized partnership audit regime is generally effective for partnership tax years beginning after December 31, 2017. As a result, the 2018 tax returns for most partnerships will be the first tax return filed under the new regime. One of the first questions partnerships, partners and tax professionals will face is determining who will be the Partnership Representative (PR). Although this would seem to be a simple question to answer, as explained below, it is much more involved than selecting a Tax Matters Partner (TMP) under the old TEFRA regime. This is especially true because any tax liability resulting from an IRS audit under the new centralized partnership audit regime is to be paid by the partnership in the current year, unless the PR takes affirmative steps otherwise. Failure by the PR to take action on a timely basis could result in a mismatch of tax burdens and tax benefits between current and former partners in a partnership.
January 23, 2019
Whitley Penn Dallas Conference... [ read ]
January 23, 2019
Henry & Peters Seminar... [ read ]
January 22, 2019
Whitley Penn Fort Worth Conference... [ read ]
January 19, 2019
2019 Midyear Meeting American Bar Association Section of Taxation... [ read ]
January 18, 2019
2019 Midyear Meeting American Bar Association Section of Taxation... [ read ]
January 11, 2019
2019 Northern District of Texas Bench Bar Conference... [ read ]
January 7, 2019
What the IRS Criminal Investigation Fiscal Year 2017 Annual Business Report Means for Tax Professionals and Taxpayers...
[ read ]
Please read the following article, "What the IRS Criminal Investigation Fiscal Year 2017 Annual Business Report Means for Tax Professionals and Taxpayers," by Josh O. Ungerman, Issn. No. 1069-1553 INSIDE BASIS at 1 (Winter 2019).
January 3, 2019
Federal Court Upholds Maximum Penalty for Willful FBAR Violation...
[ read ]
Josh Ungerman was quoted in the Bluebook article, "Federal Court Upholds Maximum Penalty for Willful FBAR Violation." Please click the link to read the article. Ryan Finley, Federal Court Upholds Maximum Penalty for Willful FBAR Violation, TAX ANALYSTS, Dec. 31, 2018.
January 3, 2019
IRS Updates Guidance on Disclosures and Accuracy Related Penalties...
[ read ]
On December 20th, the IRS released Revenue Procedure 2019-9 providing guidance on whether disclosure of an item or position taken on a tax return is adequate for purposes of reducing or eliminating the Substantial Understatement of Income Tax Penalty (IRC Section 6662(d)) and the Return Preparer Penalty (IRC Section 6694(a)). Rev. Proc. 2019-9 updates Rev. Proc. 2018-11 and makes editorial but "no additional substantive changes". Rev. Proc. 2019-9 applies to any income tax return filed on 2018 tax forms for a tax year beginning in 2018, and to any income tax return filed in 2019 on 2018 tax forms for short tax years beginning in 2019.
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