United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2017_register executive 2017-12-19 article Proposed Rules D09002ee1c7ee7028 D09002ee1c7ee72a4 United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains proposed regulations implementing 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 addressing how pass-through partners take into account adjustments under the alternative to payment of the imputed underpayment described in section 6226 and under rules similar to section 6226 when a partnership files an administrative adjustment request under section 6227. To make corresponding changes, these proposed regulations amend portions of the previously proposed regulations under sections 6226 and 6227. Additionally, these proposed regulations provide rules regarding assessment and collection, penalties and interest, and period of limitations under the new centralized partnership audit regime. The proposed regulations also address the rules for seeking judicial review of partnership adjustments. 82 FR 60144 https://www.govinfo.gov/app/details/FR-2017-12-19/2017-27071 2017-27071 fr19de17-19 RIN 1545-BO03 RIN 1545-BO04 4830-01-P REG-120232-17 REG-120233-17 https://www.govinfo.gov/app/details/FR-2017-12-19/2017-27071 https://www.govinfo.gov/content/pkg/FR-2017-12-19/html/2017-27071.htm https://www.govinfo.gov/content/pkg/FR-2017-12-19/pdf/2017-27071.pdf Employment Taxes Estate Taxes Excise Taxes Gift Taxes Income Taxes Penalties Reporting and Recordkeeping Requirements 24 p. 60144 60167 82 FR 60144 Title 26 Part 301 26 CFR Part 301 RIN 1545-BO03 RIN 1545-BO04 Centralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural Provisions; Federal Register Vol. 82, Issue PRORULE 2017-27071 DEPARTMENT OF THE TREASURY Internal Revenue Service 2018-03-19 REG-120232-17 REG-120233-17 4830-01-P 2017-27071 Notice of proposed rulemaking.

This document contains proposed regulations implementing 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 addressing how pass-through partners take into account adjustments under the alternative to payment of the imputed underpayment described in section 6226 and under rules similar to section 6226 when a partnership files an administrative adjustment request under section 6227. To make corresponding changes, these proposed regulations amend portions of the previously proposed regulations under sections 6226 and 6227. Additionally, these proposed regulations provide rules regarding assessment and collection, penalties and interest, and period of limitations under the new centralized partnership audit regime. The proposed regulations also address the rules for seeking judicial review of partnership adjustments.

Written or electronic comments and requests for a public hearing must be received by March 19, 2018. Concerning the proposed regulations under sections 6225, 6231, and 6234 of the Internal Revenue Code, Joy E. Gerdy-Zogby of the Office of Associate Chief Counsel (Procedure and Administration), (202) 317-6834; concerning the proposed regulations under sections 6227, 6232, and 6233, Steven L. Karon of the Office of Associate Chief Counsel (Procedure and Administration), (202) 317-6834; concerning the proposed regulations under sections 6226 and 6235, Jennifer M. Black of the Office of Associate Chief Counsel (Procedure and Administration), (202) 317-6834; concerning the submission of comments and a request 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: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural Provisions , www.irs.gov www.regulations.gov Vol. 82, no. 242 Office of the Federal Register, National Archives and Records Administration 2017-12-19 continuing daily deposited born digital 191 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2017-12-19 P0b002ee197d2ded9 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr19de17 https://www.govinfo.gov/app/details/FR-2017-12-19 https://www.govinfo.gov/content/pkg/FR-2017-12-19/pdf/FR-2017-12-19.pdf https://www.govinfo.gov/content/pkg/FR-2017-12-19/xml/FR-2017-12-19.xml fdlp 60099 60279 DGPO 2017-12-19 2024-06-01 FR-2017-12-19 machine generated eng FR FR-2017-12-19 82 242