The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
In August 2018, the U.S. Department of the Treasury issued final Regulations concerning the qualifications, designation, authority, and resignation of the required Partnership Representative under the new Centralized...more
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more
The IRS has released proposed regulations implementing the new centralized partnership audit rules. These regulations are virtually identical to the regulations that were released and then pulled in January of this year. ...more
The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more