Tax News & Views Corporate AMT and Podcasts Roundup

Corporate AMT

Corp. AMT Rules Could Wrap in Smaller Partnerships – Dylan Moroses, Law360 ($):

Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.

As practitioners continue to digest the 600-plus pages of proposed regulations on the U.S. corporate alternative minimum tax published this month, one early takeaway is the need for more extensive safe harbors and exceptions for partnerships that protect those entities from the CAMT calculations.

Conservation Easements

Hazy Conservation Easement Guidance Prompts Confusion, Backlogs – Tristan Navera, Bloomberg Tax ($). “Taxpayers are seeking more guidance on conservation easements as the IRS continues to disallow deductions without providing clarity on how to take them without risking a major penalty or costly litigation.”

Taxpayer Claims IRS Likely Altered Penalty Documents – Erin McManus, Tax Notes ($):

A syndicated conservation easement donor is accusing IRS counsel of revising emails to change a civil penalty approval form.

In a September 20 brief in Albero Holdings LLC v. Commissioner, the taxpayer contests when and how the revenue agent assigned to the examination of the easement donation made the determination to impose penalties on the taxpayer and when the agent’s supervisor approved those penalties.

Basis Shifting

‘Substantially Similar’ Rule for Basis Shifting Explained – Kristen A. Parillo, Tax Notes ($). “Partnership transactions that exemplify the “evils” of basis stripping are what Treasury and the IRS had in mind when defining substantially similar transactions in proposed reporting regulations on related-party basis adjustments.”

IRS Plans Transition Rules in Basis-Shifting Regs, Atty Says – Kat Lucero, Law360 ($):

The IRS plans to include transition rules in forthcoming proposed regulations that aim to clamp down on abusive tax avoidance practices through complex partnership transactions known as basis shifting, an agency attorney said Friday.

The Internal Revenue Service is aware that a transition mechanism is needed in the rules for businesses with return obligations so that they can adopt new accounting methods that are compliant with the regulations, said Clifford Warren, a pass-throughs and special industries attorney in the IRS Chief Counsel's Office.

In the Courts

IRS Is Denied Collection for Failing to Confirm Deficiency Notice – Erin McManus, Tax Notes ($). “The IRS ran up against a collection wall when it couldn’t locate the administrative file and proof that a deficiency notice was sent despite a relative’s statement that the taxpayer received the notice.”

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Tax News & Views Corporate AMT and Podcasts Roundup

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Trina Pinneau