IRS Writing Partnership Audit Guidance Based on Present Law

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.

“Right now we’re proceeding with regulations based on legislation we have,?? said Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Corporate).  “We don’t have the luxury of waiting for changes,?? he said at the American Bar Association Section of Taxation meeting in Boston.

The new audit regime aims to make the IRS’s partnership-audit and tax collection job easier by collecting tax adjustments at the partnership level instead of from individual partners.  On Capitol Hill, tax committee staffers have met with tax professionals and industry groups that want Congress to tweak some provisions, including one that allows a upper tier partnerships to push out tax adjustments to its partners.

Excerpt taken from article by Alison Bennett for Bloomberg BNA on September 30, 2016.

A New Era of Partnership Representation Before the IRS



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