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Analysis

IRS Partnership Rules Leave Single-Member LLCs In The Cold

Law360, Los Angeles (January 2, 2018, 6:52 PM EST) -- The Internal Revenue Service issued guidance last week that prevents disregarded entities, or single-member LLCs, as well as spouses, revocable trusts and others from electing out of the new partnership audit regime, a move that will restrict the number of partnerships that can bypass the new audit rules.

The final regulations, released Friday, clarified when partnerships can elect out of the partnership audit regime under the Bipartisan Budget Act of 2015, or BBA, which went into effect Monday and generally assesses taxes at the partnership level...
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