June 21, 2018
A federal tax lien attaches to all real and personal property of a taxpayer at the time an assessment is made by the Internal Revenue Service and continues until the liability is paid or becomes unenforceable by reason of a lapse of time (10 years). The lien is a statutory lien that is perfected as to the taxpayer at the time the tax is assessed. As to third parties, the lien is only perfected if properly filed in the appropriate filing office under state law. In South Carolina, a federal tax lien is perfected when filed with the Register of Deeds in the county where the taxpayer owns real (or personal) property.
January 16, 2018
The IRS has issued final regulations under IRC § 6221(b), implementing rules for electing out of the new centralized partnership audit regime enacted under the Bipartisan Budget Act of 2015. The final regulations under IRC § 6221(b) are effective for partnership tax years beginning after December 31, 2017, the same effective date of the new partnership audit regime.