Partnership Aggregate-Entity Summary of Authorities

Updated Feb. 8, 2023

1. General Principle of Law

The general principle of law underlying aggregate or entity treatment of a partnership is set forth in the 1954 Conference Report on Section…

Auditing and Tax Do Not Play Well Together

Updated Feb. 8, 2023

Recent news reports have disclosed the accounting firm Ernst & Young’s (EY) purported plan to separate its consulting business from its global audit practice. (Mark Maurer and Jean Eaglesham, “Accounting Firm…

The Partnership Anti-abuse Rule and UpReit Structures Revisited

Taxpayers are straying outside the lines when it comes to so-called UP structures, whose name derives from the umbrella partnership real estate investment trust (UpReit), but can also involve C corporations (Up-Cs) and…

Federal Income Tax Treatment of The Sale of A Partnership Interest By A Nonresident Of the U.S.

In Rawat (Rawat v. Commissioner, T.C. Memo 2023–14, Tax Court Judge David Gustafson, who also authored the opinion in Grecian Magnesite (Grecian Magnesite Mining…

Regulation Examples Not Supported By Text: A Partnership Response

In his interesting recent Tax Notes article on regulation examples being promulgated without supporting regulatory text (Jasper L. Cummings, “Regulation Examples Are Not Guidance”, Tax Notes Federal, Jan. 16, 2023…