Entity Classification Internal Revenue Code

New Partnership Audit Rules

The Bipartisan Budget Act (“Act”) was signed into law on November 2, 2015 amending the rules concerning how entities taxed as partnerships will be audited by the IRS and who…

Entity Classification Internal Revenue Code Internal Revenue Service

Changes to the § 108 Exclusion Rule

Normally, under Internal Revenue Code § 61(a)(12), income from the discharge of indebtedness is includable in gross income, however, such income may be excludable from gross income under certain exceptions…

Business Court Case Elections Entity Classification Tax Compliance

S-corporations, Nonresident Aliens and Community Property Laws

An S-corporation is a business entity in which all of the corporate income, losses, deductions, and credits each year are passed through to the shareholders for federal tax purposes.  Shareholders…

Entity Classification Forms and Filings International Taxation

Substantial Presence Test

Global families residing in multiple countries may run the risk of being considered a resident alien (“RA”) of the United States for tax purposes even without obtaining a green card. …