New IRS Priority Guidance Indicates Potential Guidance Concerning Multi-Tier Push Out
The Department of the Treasury and Internal Revenue Service released their latest priority guidance plan on October 20, 2017. Part 3 of the plan addresses the Partnership Audit Regulations and the new rules the agency wants to implement to form a new partnership audit regime. Interestingly, the guidance identifies the need for “Regulations addressing push out election by tiered partnerships.?? The need for such guidance has been a critical concern from industry practitioners.

A New Era of Partnership Representation Before the IRS



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