IRS Re-releases Proposed Regulations to Implement New Partnership Audit Rules

The IRS on Jun 13, 2017, re-released Proposed Regulations (REG-136118-15) to implement the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (P.L. 114-74, Nov 2, 2015) (BBA rules). The newly released version of the Proposed Regulations is essentially the same...

Full description

Saved in:
Bibliographic Details
Published in:Journal of International Taxation 2017-08, Vol.28 (8), p.16
Main Authors: McArthur, Todd Y, Gerson, Craig, Hauswirth, Michael J
Format: Article
Language:English
Subjects:
Audits
C corporations
Disregarded entities
Federal legislation
International taxation
Nominations
Partnerships
Proposals
Tax regulations
TEFRA 1982-US
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:The IRS on Jun 13, 2017, re-released Proposed Regulations (REG-136118-15) to implement the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (P.L. 114-74, Nov 2, 2015) (BBA rules). The newly released version of the Proposed Regulations is essentially the same as the version that was released unofficially in January 2017 and then withdrawn in response to an executive order that the incoming Administration issued. Under the BBA rules, tax on any adjustment that results in an increase to a partnership's income (an imputed underpayment) is assessed on and collected from the partnership unless the partnership elects to "push out" the adjusted items to its partners by providing a statement to each person that was a partner in the year under review, reporting such person's share of the adjustment. The Proposed Regulations clarify that the consistency requirements apply to a partner that is itself a partnership, regardless of whether the upper-tier partnership elected out of the BBA rules.
ISSN:1049-6378