Proposed Partnership Audit Regulations Liberalize Push-Out Rules
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- The IRS reversed its position on frustrating the application of the push-out election to tiered partnership structures. The latest proposed regulations now allow pass through partners to decide whether to continue pushing adjustments out to the next tier of affected partners in the chain or to pay the tax resulting from the adjustment.
- The IRS dispensed with the requirement in the original proposed regulations that required partnerships to provide partners with information enabling them to pay a safe harbor amount.
- The IRS has not changed its narrow view on partnerships that may elect out of the centralized partnership audit regime. A partnership with a partner that is a partnership or even a disregarded entity will not be allowed to elect out of the regime.