IRS Releases Interim Guidance Centralized Partnership Audit Regime

The IRS provided interim guidance under Internal Revenue Manual 4.31.9 that would provide field examination procedures for centralized partnership audit regime until new IRM is published. The guidance applies to partnerships for taxable years beginning after December 31, 2017, and partnerships that elect into the Bipartisan Budget Act of 2015 (BBA) regime for taxable years beginning after November 2, 2015, and before January 1, 2018. The guidance is effective October 31, 2019. [LB&I-04-1019-010 (Oct. 24, 2019)].

A New Era of Partnership Representation Before the IRS

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