Bradley attorney Bruce Ely was quoted in Law360 on new partnership tax audit rules that took effect at the beginning of the year. The IRS and the Treasury Department have released some regulations on how they plan to implement the new regime, but tax specialists say gaps remain in guidance that need to be filled.
“Perhaps the most important issues we hope Treasury will address next are the treatment and calculation of capital accounts and basis adjustments, and we certainly hope to see those addressed in the next batch of proposed regs,” said Ely. “Another unresolved issue — at least in many tax practitioners’ minds — is whether a partnership representative must be appointed if his or her singular role is to check the box to elect the partnership out of the partnership audit rules. It’s a chicken-and-egg dilemma."
The complete article, “Clarity Needed As New Partnership Tax Regime Takes Effect,” appeared in Law360 on January 10, 2018.