In this Ropes & Gray webinar, tax partners Kat Gregor and Jim Brown and moderator Kathryn Seevers discuss the trilogy of proposed partnership audit regulations that provide rules implementing many aspects of the provisions of the Bipartisan Budget Act of 2015. The most notable set of regulations allows for “push-out” elections to be effective in
New Partnership Audit Regulations Released as Permitting Push-Out Election Through Tiered Partnerships
In a trilogy of releases in the last six weeks, the Department of Treasury (“Treasury”) provided much-needed guidance on the implementation of the partnership audit rules in the Bipartisan Budget Act of 2015 (the “BBA Rules”). On the eve of the BBA Rules coming into effect (for tax years beginning after December 31, 2017), Treasury
New Partnership Audit Regulations Released as Effective Date Draws Near
On November 29, 2017, the Department of Treasury (“Treasury”) issued proposed regulations (REG-119337-17) addressing certain international tax aspects of the centralized partnership audit regime passed into law in the Bipartisan Budget Act of 2015 (the “BBA Rules”). The newly proposed regulations provide rules addressing FATCA and other tax withholding on foreign partners and the treatment of certain foreign tax payments made by a partnership. The newly proposed regulations are one piece of guidance expected from Treasury as the BBA Rules come into effect for partnership tax years beginning after December 31, 2017.
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Comments on the New Partnership Audit Regime
In September 2017, the American Bar Association (“ABA”) Section of Taxation submitted comments to the IRS on proposed regulations implementing the partnership audit procedures enacted as part of the Bipartisan Budget Act of 2015. Ropes & Gray was honored to play a role in the drafting of these comments, an effort lead by the ABA
One Step Closer: An Update on Partnership Audit Reform in the United States
In the April-June 2017 issue of Risk & Compliance, Tax partner Kat Gregor and Tax associates Kathryn Seevers and Veronika Polakova discuss certain governance concerns raised by the new partnership audit regulations that were released by the Department of Treasury on January 18, 2017. The article focuses on two issues: (1) the ability of