Bradley Partner Bruce Ely Featured in Bloomberg BNA on How Practitioners Are Responding to Partnership Audits
State and Local Tax (SALT) attorney Bruce Ely was featured in Bloomberg BNA on how practitioners are responding to a federal law that modified rules governing federal audits of partnership entities. A task force of the American Bar Association (ABA) tax section's State and Local Tax Committee partnered with an AICPA work group on a project to address state implications from the federal law.
Ely, co-chair of the ABA task force, presented a memorandum generally urging state conformity and advocating for a model revenue agent report (RAR) statute. However, the task force recommended states allow an opt-out from the Section 6226 push-out election and Section 6225 “pay-up election"—intended to reduce administrative burdens by retaining liability with the partnership.
The complete article, “New Federal Take on Partnership Audits: A Primer,” appeared in Bloomberg BNA on December 8, 2016.