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2017-06-14
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Centralized Partnership Audit Regime
Part II
Proposed Rules
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D09002ee1bdbc133b
United States
Department of the Treasury
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org
United States Government Agency or Subagency
United States
Internal Revenue Service
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org
United States Government Agency or Subagency
This document contains proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules for partnerships subject to the new regime, including procedures for electing out of the centralized partnership audit regime, filing administrative adjustment requests, and the determination of amounts owed by the partnership or its partners attributable to adjustments that arise out of an examination of a partnership. The proposed regulations also address the scope of the centralized partnership audit regime and provide definitions and special rules that govern its application, including the designation of a partnership representative. The proposed regulations affect partnerships for taxable years beginning after December 31, 2017 and any partnerships that elect application of the centralized partnership audit regime pursuant to Sec. 301.9100-22T for taxable years beginning after November 2, 2015 and before January 1, 2018. This document also provides notice of a public hearing on these proposed regulations. This document also withdraws the notice of proposed rulemaking published in the Federal Register on February 13, 2009 (74 FR 7205), regarding the conversion of partnership items related to listed transactions.
82 FR 27334
https://www.govinfo.gov/app/details/FR-2017-06-14/2017-12308
2017-12308
fr14jn17-24
RIN 1545-BN77
4830-01-P
REG-136118-15
https://www.govinfo.gov/app/details/FR-2017-06-14/2017-12308
https://www.govinfo.gov/content/pkg/FR-2017-06-14/html/2017-12308.htm
https://www.govinfo.gov/content/pkg/FR-2017-06-14/pdf/2017-12308.pdf
Employment Taxes
Estate Taxes
Excise Taxes
Gift Taxes
Income Taxes
Penalties
Reporting and Recordkeeping Requirements
69 p.
27334
27402
82 FR 27334
Code of Federal Regulations
Title 26 Part 301
26 CFR Part 301
Regulation Identification Number 1545-BN77
RIN 1545-BN77
Centralized Partnership Audit Regime; Federal Register Vol. 82, Issue
PRORULE
2017-12308
II
DEPARTMENT OF THE TREASURY
Internal Revenue Service
2017-08-14
2017-09-18
REG-136118-15
4830-01-P
2017-12308
Notice of proposed rulemaking, notice of public hearing, and withdrawal of notice of proposed rulemaking.
This document contains proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules for partnerships subject to the new regime, including procedures for electing out of the centralized partnership audit regime, filing administrative adjustment requests, and the determination of amounts owed by the partnership or its partners attributable to adjustments that arise out of an examination of a partnership. The proposed regulations also address the scope of the centralized partnership audit regime and provide definitions and special rules that govern its application, including the designation of a partnership representative. The proposed regulations affect partnerships for taxable years beginning after December 31, 2017 and any partnerships that elect application of the centralized partnership audit regime pursuant to Sec. 301.9100-22T for taxable years beginning after November 2, 2015 and before January 1, 2018. This document also provides notice of a public hearing on these proposed regulations. This document also withdraws the notice of proposed rulemaking published in the Federal Register on February 13, 2009 (74 FR 7205), regarding the conversion of partnership items related to listed transactions.
Written or electronic comments must be received by August 14, 2017. Outlines of topics to be discussed at the public hearing scheduled for September 18, 2017, at 10 a.m. must be received by August 14, 2017.
Concerning the proposed regulations, Jennifer Black of the Office of Associate Chief Counsel (Procedure and Administration), (202) 317-6834; concerning the submission of comments and requests for a public hearing, Regina Johnson, (202) 317-6901 (not toll-free numbers).
Employment Taxes
Estate Taxes
Excise Taxes
Gift Taxes
Income Taxes
Penalties
Reporting and Recordkeeping Requirements
Centralized Partnership Audit Regime
,
www.irs.gov
www.regulations.gov
Federal Register
Vol. 82, no. 113
Office of the Federal Register, National Archives and Records Administration
2017-06-14
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308 p.
Table of Contents:
AE 2.7:
GS 4.107:
AE 2.106:
KF70.A2
https://www.govinfo.gov/app/details/FR-2017-06-14
P0b002ee19531b673
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0042-1219
0364-1406
769-004-00000-9
000582072
f:fr14jn17
https://www.govinfo.gov/app/details/FR-2017-06-14
https://www.govinfo.gov/content/pkg/FR-2017-06-14/pdf/FR-2017-06-14.pdf
https://www.govinfo.gov/content/pkg/FR-2017-06-14/xml/FR-2017-06-14.xml
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