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ARTICLE · 28 JUNE 2017

IRS Reissues Proposed Regulations For Centralized Partnership Audit Regime

Morrison Foerster
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The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements...

United StatesAccounting and Audit
Thomas Humphreys
Thomas Humphreys
David Strong
David Strong
Remmelt Reigersman
Remmelt Reigersman
Shane Shelley
Shane Shelley
Craig Phillips
Craig Phillips
Brennan Young
Brennan Young
Shannen Naegel
Shannen Naegel
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The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect on January 1, 2018. Participants in M&A transactions involving partnerships should also consider the potential impact of the new rules.

On June 13, 2017, the Internal Revenue Service ("IRS") re-released proposed regulations (the "Proposed Regulations")1 implementing the centralized partnership2 audit regime enacted into law under the Bipartisan Budget Act of 20153 (the "Budget Act").4 The Proposed Regulations are nearly identical to regulations proposed in January of this year (the "January Proposed Regulations"), which were withdrawn as part of a regulatory freeze by the Trump administration.5

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