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George Hani Comments on Partnership Audit Rule Corrections in Tax Notes Today

Subtitle
"Omnibus Partnership Audit Rule Corrections Strike Familiar Tone"

Tax Notes Today

George Hani commented on the recently enacted Consolidated Appropriations Act, 2018 (H.R. 1625), which includes technical corrections to the new partnership audit regime established under the Bipartisan Budget Act of 2015. The recent changes will cause a delay in the much anticipated guidance process, Hani said, adding "Treasury and the IRS were certainly aware of these items, but now that they are real, they will need to revisit impacted provisions." The clarity the bill provides regarding push out adjustments follows proposed regs released in December permitting partnerships to push out adjustments through tiers. The bill, which would fix the "ups and downs" in intervening years when a push-out election is made, would be well received, Hani said. "Now taxpayer-favorable correlative adjustments in intervening years can be taken into account," he said, adding that the pull-in modification was likewise helpful, as it would get the result of an amended return without incurring the expense or effort required in filing one.