Electing into New Partnership Audit Rules

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As previously discussed (here), TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.  The new audit rules allow for an earlier effective date if the partnership so elects (although few partnerships would likely want to do so).

A Treasury official  stated during last week’s ABA Tax Section meeting that guidance on how to elect into these new audit rules is expected very soon.  A more comprehensive notice of proposed rulemaking is then expected to follow.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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