Newsflash: Newly Proposed Partnership Audit Rules Allow for Multiple-Tier “Push-Out” Election

December 18, 2017

The U.S. Department of the Treasury (the “Treasury”) and the U.S. Internal Revenue Service (the “IRS”) have issued a new installment of proposed regulations under the centralized partnership audit regime included in the Bipartisan Budget Act of 2015 (the “Bipartisan Budget Act”). The newly proposed regulations address how certain pass-through partners take into account adjustments under the “push-out” election of Section 6226 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”), as amended by the Bipartisan Budget Act. The proposed regulations also provide rules regarding assessment and collection, penalties and interest, and period of limitations under the new centralized partnership audit regime, as well as rules for seeking judicial review of adjustments made pursuant to the new regime.

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