Partnership Representative

Technical corrections to the new regime for auditing partnerships aren't likely to happen this year, as Congress is looking to wrap up 2016 quickly with a short-term spending bill and little else...

A law intended to make it simpler for the Internal Revenue Service to audit partnerships may turn out to be problematic for the agency to administer, the IRS chief said. Commissioner John Koskinen said it’s possible that taxpayers and the agency might be worse off under the new system because “nobody quite asked, ‘Hey, would this really work?’?? before the legislation was passed...

On October 4, 2016, the Treasury Department and Internal Revenue Service (IRS) issued revised regulations governing how recourse partnership liabilities are allocated among partners. These temporary regulations, which are binding on taxpayers immediately, relate to so-called “bottom-dollar payment obligations?? (BDPOs)...

The AICPA recently released comments and recommendations in response to Notice 2016-23, Request for Comments Regarding Implementation of the New Partnership Audit Regime Enacted as Part of the Bipartisan Budget Act of 2015, issued on March 4, 2016. Visit this link for the expanded version. Below is an outline of the AICPA comments and recommendations...

Caplin & Drysdale’s Charles M. Ruchelman spoke with Bloomberg BNA’s Laura Davison regarding the potential for investment in partnerships declining and S corporation status gaining in popularity if neither Congress nor the IRS revise a disputed provision in the new partnership audit regime about how far a multitiered entity can push out an adjustment...

The Internal Revenue Service is moving forward with regulatory guidance on the new partnership audit and tax collection regime as it was enacted last year, even as controversy continues in Congress and among practitioners about whether technical corrections are necessary, an IRS official said on September 30, 2016...

Speaking at an energy tax conference in Houston on September 20th, top IRS official Cheryl Claybough said the IRS is in the process of completing proposed regulations to implement new partnership audit rules and hopes to issue those regulations by the end of 2016. The government wants to issue the new regs by the end of 2016...

Yesterday (August 4, 2016), the Treasury Department issued its first regulations under the new partnership audit and collection regime found in the Bipartisan Budget Act of 2015. For partnership tax procedures practitioners like me, the regulations are fascinating. While the new regulations will not impact many partnerships and limited liability companies, as the real substantive guidance is forthcoming, the new regulations provide insights into the internal deliberations at IRS headquarters...