05 August 2016 Law firm clients: IRS regulations specify procedures for electing into new partnership audit regime The IRS has issued temporary (TD 9780) and proposed (REG-105005-16) regulations setting forth the time and manner for electing to apply the new partnership audit regime enacted by the 2015 Bipartisan Budget Act (BBA), for partnership tax years beginning after November 2, 2015 (the BBA enactment date) and before January 1, 2018. This is the first in a series of regulations to be issued under the new audit regime. While the regulations do not address the substantive provisions, this is a key first step in the IRS and Treasury's release of guidance implementing the new audit regime before January 1, 2018. More guidance, however, is necessary to fully understand whether an election into the new audit regime would be beneficial for the eligible tax years. Law firms and their partners will need to carefully analyze their specific facts and circumstances in determining whether to make the election (after receipt of a notice of selection for examination for a tax year beginning after November 2, 2015). For details on the new regulations, see Tax Alert 2016-1344.
Document ID: 2016-1357 | |||||||||||
