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.