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The recent emphasis by the Internal Revenue Service (IRS) to stop abusive tax shelters has brought about an onslaught of regulation [citation needed]. Aggregate and Entity Concept The Federal income taxation of partners and partnerships is set forth under Subchapter K covering Sections 701–777 of the Code.
When this happens, the old partnership may or may not be dissolved and a new partnership may be created, with a new partnership agreement. For US tax purposes, a technical termination may be caused if more than 50% of the partnership interests change hands in the same (US) tax year. A new partner may buy into the business in three ways:
A partner's tax basis in the partnership generally equals the adjusted basis of property contributed or cash paid plus any income recognized by the partner on the formation of the partnership, plus the partner's share of the liabilities of the partnership under 26 U.S.C. § 752. Such income may arise from services performed in exchange for the ...
The IRS plans to end a major tax loophole for wealthy taxpayers that could raise more than $50 billion in revenue over the next decade, the U.S. Treasury Department says. The proposed rule and ...
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The Internal Revenue Bulletin (also known as the IRB), [1] [2] is a weekly publication of the U.S. Internal Revenue Service that announces "official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest."
The IRS Internal Revenue Manual is the official source of instructions to IRS personnel relating to the organization, administration and operation of the IRS. The IRM contains directions IRS employees need to carry out their responsibilities in administering IRS obligations, such as detailed procedures for processing and examining tax returns.
According to the IRS, a Group Exemption Letter is a ruling or determination letter that is issued to a central organization recognizing, on a group basis, the exemption from Federal income tax under 26 U.S.C. § 501(c) of subordinate organizations on whose behalf the central organization has applied for recognition of exemption.