Page 488 - TaxAdviser_2022

Volume 53, Number 10 October 2022

TAX CLINIC

Employee retention credit:
Navigating the suspension test ...... 7
Key proposed provisions of
‘SECURE 2.0’ ............................... 10
Rembrandt and retirement:
The pitfalls of collectibles and
self-directed IRAs ......................... 11
US clients with international
tax issues: Five helpful tips .......... 13
Capital loss rules limit
deduction of fees paid to
terminate merger agreement ....... 15
Partnership examinations:
Imputed underpayment
modification ................................. 17

Real estate partnership
restructuring and potential
disguised sales ............................. 19

Target capital account
24 10 good reasons why LLCs should not allocations in 11 easy steps ......... 20
elect to be S corporations Rolling over shares upon

By Paul N. Iannone and Danny A. Pannese S corporation’s acquisition .......... 22
The owners of an LLC may be tempted to have the LLC elect to be treated as an S
corporation for federal tax purposes. However, there are a host of issues that should DEPARTMENTS
be considered before making this move. In this article, the authors discuss 10 reasons
why it may not be beneficial for an LLC to make an S corporation election.
TAX PRACTICE &
34 Publicly traded partnerships: Investors’ PROCEDURES ............................. 40
tax considerations DC CURRENTS ............................ 44
By Laura Hinson and Kathryn Neely CASE STUDY ................................ 48
Interests in publicly traded partnerships (PTPs) can be a valuable part of an inves-
tor’s portfolio, but because these investments are partnership interests, the tax report- TAX TRENDS ................................ 52
ing for them can be complex, and losses passed through by PTPs may be limited.
This article discusses the tax compliance and loss limitation issues involved with, and Tax News
tax planning considerations for, holding interests in PTPs.
For the latest tax news, visit
TheTaxAdviser.com.
On the cover On the cover and above: Images by Hector Roqueta Rivero/Getty Images

2 October 2022 The Tax Adviser