Are IRS partnership audits really going away? Treasury performance data show partnership examination starts fell about 76% from fiscal year 2023 to fiscal year 2025, but IRS partnership audits are still live for the biggest partnerships, and the Bipartisan Budget Act regime still bills the partnership itself when one lands. A client calls after reading…
How do partnership merger tax rules work under Sec. 708(b)(2)(A)? A resulting partnership is a continuation of any merging partnership whose partners own more than 50% of the capital and profits of the resulting partnership; other merging partnerships terminate. Consideration mixing cash and interests triggers disguised-sale analysis, and the merger cash-out rule at Regs. Sec….
When is the BBA partnership push-out deadline for a pass-through partner? If you received a Form 8986 tied to a partnership that filed an Administrative Adjustment Request (AAR) or was audited under the BBA partnership audit regime, the deadline to pay or push out further is generally September 15, 2026 — the exact date is…
