TEFRA

Issues and considerations in appointing a partnership representative

This item discusses issues partnerships and their advisers should consider when designating a PR or DI, accounting for the potential for conflicts of interest, whether and to what extent limitations can be placed on the PR or DI, and how these roles differ dramatically from that of the TMP.

Rules determine who can be a partnership representative under new audit regime

The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.

Final regs. govern who can be a partnership representative

The IRS finalized proposed regulations under Sec. 6223 on the procedures for designating a partnership representative and the authority of the partnership representative under the centralized partnership audit regime.

IRS issues final regs. on electing out of centralized partnership audit regime

The regulations’ definition of an ‘eligible partner’ is key to determining whether a partnership can elect out of the centralized partnership audit regime.

Appropriations act tax provisions include IRS funding and audit rules

The $1.3 trillion spending bill passed by Congress includes IRS funding and tax-related technical corrections, including changes to the centralized partnership audit regime.

AICPA issues TQA on accounting for payments under the centralized partnership audit regime

The technical question and answer helps financial statement preparers account for the amount a partnership pays the IRS for previous underpayments of tax, interest, and penalties.

AICPA recommends flexibility in partnership audits

The IRS should provide a simplified adjustment procedure for partnership audits, the AICPA recommended in a letter to the IRS Chief Counsel’s Office.

Proposed regs. would govern partnership audit adjustments

The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.

IRS issues final rules on election out of centralized partnership audits

IRS final regulations govern electing out of centralized partnership audits.

Partnership audit adjustments addressed in proposed regs.

The IRS issued proposed regulations addressing how partnerships and their partners adjust tax attributes to take into account partnership adjustments under the new centralized partnership audit regime.

Current developments in partners and partnerships

This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.

Final rules govern election out of centralized partnership audits

The IRS finalized the rules for determining whether partnerships are eligible to elect out of the centralized audit procedures enacted in 2015, which apply to partnerships this year.

Developing a uniform state approach to the new federal partnership audit regime

This column, the first of two parts, discusses issues states must consider and steps some have taken to align partnership audit rules with new federal rules.

IRS reissues centralized partnership audit rules

The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.

Penalties for inconsistent reporting subject to deficiency procedures

Where there are no adjustments to partnership items, a taxpayer could not hide behind the Sec. 6230(a)(2)(A)(i) exclusion.

Centralized partnership audit rules are reissued in proposed form

The IRS reissued proposed regulations governing the centralized audit rules, which assess and collect tax at the partnership level.

State Challenges With the New Federal Partnership Audit Rules

The AICPA Task Force is developing a position paper with possible approaches that state CPA societies may want to consider in working with state legislatures and tax authorities in developing compliance policies.

Current Developments in Partners and Partnerships

This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.

Centralized Partnership Audit Rules Proposed

The IRS released a package of proposed provisions that will apply to the recently enacted centralized audit regime that generally assesses and collects tax at the partnership level.

New Partnership Audit Procedures Will Have a Profound Impact

Changes in the the Bipartisan Budget Act of 2015 are a departure from how partnerships have been treated for federal income tax purposes.
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