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Fine-Tuning The New Partnership Audit Regime

Law360 (May 4, 2018, 10:13 AM EDT) -- The omnibus appropriations bill signed into law on March 23, 2018, included several technical corrections to the new partnership audit regime, originally enacted in 2015, effective for partnership taxable years beginning in 2018. Many of the technical corrections were included in a technical corrections bill proposed in 2016 but never enacted. Other changes echo proposed regulations promulgated in 2017, giving legislative authority to those rules. Key among the technical corrections are authorization to use a push-out procedure in tiered partnerships, a new “pull-in” procedure, and rules...
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