Bradley Partner Bruce Ely Quoted in State Tax Notes on Prefiled Montana Bill Addressing IRS Partnership Rules
State Tax Notes
State and Local Tax (SALT) attorney Bruce Ely was quoted in State Tax Notes on a prefiled bill in Montana that addresses the new IRS partnership audit regime. The bill is in response to the federal government’s enactment of a new approach that will allow the IRS to assess and collect tax due on partnership adjustments at the entity level. Ely explained that practitioners were hoping that the states would take a wait-and-see approach in light of consistent advice given by the Multistate Tax Commission (MTC) and the IRS commissioner.
“The rules are not effective until next year, and obviously there won’t be any immediate IRS audits, so there’s no need to pass attempted conformity legislation this year or even next,” Ely said. “That’s especially true when it’s almost a near certainty that Congress will pass a technical corrections bill next year, and we expect to receive some key guidance from the IRS as well.”
The complete article, “Prefiled Montana Bill Would Address New IRS Partnership Audit Regime,” appeared in State Tax Notes on December 27, 2016. (login required)