Proposed Regulations – Disguised Payments

New Proposed Regulations Concerning Disguised Payments to Partners for Services: Part II (Targeted Capital Accounts) Background Our August 6th article, “Proposed Regulations Concerning Disguised Payments to Partners”, described the new proposed regulations that treat certain payments to service partners as compensatory payments rather than as partnership distributions.  The proposed regulations particularly focus on the amount…

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Regulations Concerning Disguised Payments To Partners

New Proposed Regulations Concerning Disguised Payments to Partners for Services Background A partner can act in more than one capacity with respect to its partnership, that of a partner or that of a third-party.  For example, if a partner contributes property to the partnership in exchange for an increased ownership interest the transfer represents a…

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Construction Deductions and Taxes

Previously, we discussed the tax impact of construction allowances on tenants and landlords, including the application of Revenue Code (“IRC”) §110. IRC §110 treatment is not “elective.” However, the regulations add an important additional requirement interpreting the statute’s broad statement that the portion of the construction allowance subject to IRC §110 is that intended for…

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Tax Advantages: Build Yourself Or Let Tenant?

Tenant and Leasehold Improvements: The Tax Impact of Construction Allowances from the Landlord’s Perspective A landlord leasing commercial space can either directly improve or finish-out the tenant’s space or provide the tenant with a construction allowance so that it can arrange for its own finish-out. One can correctly observe that there is no real substantial…

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Partnership and LLC Tax Allocation

April 15th was the deadline for federal and most state income tax returns! Note that Texas annual franchise tax reports are due May 15, 2015. Taxpayers can file the Texas franchise tax report or request an extension of time to file electronically using the WebFile system, which makes it easy to request extensions, submit tax…

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New Summer Office Hours

Dear Clients: We wanted to let you know that our office will be closed this Friday, April 17th. We will be back in the office on Monday, April 20th. We will also start our shorter work week on Monday, April 20th. That is, we will be working one extra hour each day, Monday – Thursday,…

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Applying TPRs and Form 3115

In my last newsletter/blog, I wrote that in connection with the preparation of our clients’ 2014 tax returns, we will do an analysis of, and have discussions about, applying the TPRs to 2014, which may lead us to discussions about filing the Forms 3115 for certain entities if we think there may be some additional…

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Do You Need To File Form 3115?

Late in the afternoon of Friday, February 13th, the IRS released Revenue Procedure 2015-20 that dramatically changed the implementation of the tangible property regulations (TPRs), which I have been writing about. (Read the previous blog here) The new revenue procedure provides that for each taxpayer’s separate and distinct trade or business with total assets of…

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Form 3115 – TPRs – Tangible Property Regulations

The IRS and the US Treasury issued final tangible property regulations (TPRs) that become effective, as an option, for the first time, for business 2012 and/or 2013 tax returns, but mandatory for this tax year 2014. These TPRs will most likely require all business taxpayers to file additional IRS forms and supporting statements for 2014…

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2015 Tax Amendments

Happy New Year! Prepping for 2014 Tax Returns

As we get ready for preparing our clients’ 2014 tax returns, we have extra work to do regarding the new “repair regulations,” which I wrote about last month. The new rules require analysis to be done, plus election statements and change in accounting method forms are required to be included in the 2014 tax returns.…

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