George Hani was quoted regarding proposed regulations under the Internal Revenue Service's (IRS's) new partnership audit regime that would permit partnerships to push out adjustments through multiple tiers. "I think it's very favorable that they're allowing multiple push-outs all the way to the ultimate taxpaying individual or entity," Hani said. The proposed regulation is designed to provide flexibility for passthrough partners by creating a mechanism for each partner in the ownership chain to either pay the tax associated with an adjustment or push the adjustment to its partners. "I think the rules are complicated, but the optionality is a good thing," he said, adding that the rule gives partnerships a "choice of whether they want to endure the complication to get to the right number and right person, or just for administrative ease, pay at the entity level." Passthrough partners must send statements with an array of identifying information to push out adjustments or take them into account, but the proposed regs do not require the partnership making the initial push-out election to assemble all the information, Hani said. "It's collected as you push out through each tier, so the lower-tier partnership isn't required to find out who the ultimate owners are, which would have been unrealistic." A positive aspect of the push-out regime is that a partnership making a push-out election is relieved of liability for the adjustment if it makes the election properly and complies with the other requirements, Hani said, adding that, "it's the party that receives the statement that is now on the hook for any tax due or compliance failures."