Bradley attorney Bruce Ely was quoted in State Tax Notes on a request from the American Institute of CPAs (AICPA) to delay the effective date of the new centralized federal partnership audit regime, citing among its reasons the impact on state tax law. In a letter to Congress, the AICPA said Treasury and the IRS have not yet provided all necessary procedures and guidance for taxpayers to make informed decisions.
“While I applaud the AICPA’s efforts, most of us tax practitioners aren’t very optimistic that Congress will take this up at this late date, since the rules are now effective and two new batches of implementing regulations were issued in the past few weeks,” said Ely, former chair of the ABA SALT Committee task force. Ely also provided observations about the proposed regulations allowing a tiered partnership to push adjustments beyond the first-tier partners.
“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,” Ely said. Amendments to the basis adjustment rules included in the federal tax reform law must now be factored in, he added.
The complete article, “AICPA Asks Congress to Delay New IRS Partnership Audit Regime,” appeared in State Tax Notes on January 5, 2018. (login required)