partnership tax


Court Says No Tax Due on Foreign Corporation’s Redemption of U.S. Partnership Interest

Many businesses that operate outside of the U.S. want to do business in the U.S. and they want to limit their exposure to U.S. income taxes. To do this, many in-bound investments are structured as U.S. partnerships with the parntership …..

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Issue for the New Partnership Audit Procedures Raised in TEFRA Case

The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) procedures were intended to make it easier for the IRS to audit partnership tax returns. TEFRA failed to deliver. The rules are nuanced and hard to apply. The new partnership …..

The post Issue for the New Partnership Audit Procedures Raised in TEFRA Case appeared first on Houston Tax Attorney.


Partnership Tax Return Cannot be Corrected by Amended Tax Return

In U.S. v. Stewart, No. 15-20596, the Fifth Circuit Court of Appeals concluded that the taxpayer was not entitled to a tax refund that was based on a corrected Schedule K-1 received from a partnership the taxpayer owned. The question on appeal was whether a partnership tax return can be corrected by filing an amended […]

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