Linda Carlisle's Comments During PLI Partnership Tax Planning Conference Quoted in Tax Notes

"Criticizing the New Partnership Audit Rules' 'Rough Justice'"
Tax Notes
04.29.16Linda Carlisle's comments during a Practising Law Institute (PLI) conference on partnership tax planning on April 27, 2016, were quoted in Tax Notes. The new partnership audit rules, contained in the Bipartisan Budget Act of 2015 (BBA), allow the Internal Revenue Service (IRS) to assess tax due on partnership adjustments at the entity level. During a discussion of the effective date of the new rules, Carlisle asked whether the IRS anticipates anyone making an early election into the entity-level tax regime noting that the traditional closing agreement option that enables a partnership to pay at the entity level will remain available.
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