In a recent decision with potentially broad implications, the Texas Supreme Court held in favor of a taxpayer on a question involving the treatment of capital losses for purposes of the Texas franchise tax. In Hallmark...
Category: Blog
Another Cautionary Tale for Executors, Trustees, and Beneficiaries: Liability for Unpaid Estate Taxes
The United States District Court for the Eastern District of California has issued an opinion finding that the executors of the estate, the trustees of the family trust, and the beneficiaries of the estate who received...
Taxpayers Beware! Partnerships Should Consider Amending Their Agreements Now to Address Significant Issues Resulting From the New Partnership Audit Rules
As discussed in a recent blog post¹, a new partnership audit regime that was enacted as part of the Bipartisan Budget Act of 2015 (the “Partnership Audit Rules”) will have significant, wide ranging effects on the...
Master Limited Partnerships and Cancellation of Indebtedness Income
A Master Limited Partnership (“MLP”) is an investment vehicle used in oil and gas, and several other industries. MLPs are designed to avoid corporate level taxation; however, this comes at a price that many investors have...
Texas Bar Tax Section Issues Comments Regarding New Partnership Audit Rules
On April 26, 2016, the Tax Section of the State Bar of Texas (“Tax Section”) submitted to the Internal Revenue Service comments (the “Comments”) regarding the implementation of the new partnership audit regime (the...