Proposed regulations lay out framework for future partnership audits and collection

Treasury and the IRS released proposed regulations implementing the new centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015, which replaces the partnership audit rules of the Tax Equity and Fiscal Responsibility Act of 1982. These proposed regulations are substantially similar to draft proposed regulations that were released publicly by the IRS in January 2017, but were withdrawn before being published in the Federal Register as part of the new Trump administration’s initial freeze on regulatory activity.   

For more information, see this Tax Flash.

David Auclair
National Managing Principal-WNTO,
Washington National Tax Office
T +1 202 861 4144

Grace Kim
Principal, Washington National Tax Office
T +1 202 521 1590

Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.

The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.