George Hani was quoted regarding additional regulatory changes by the Internal Revenue Service (IRS) to partnership audit rules, beyond those that were signed into law with the Consolidated Appropriations Act (CAA) in March. While the IRS and Department of the Treasury changes should be minor, Congress enacted some novel concepts that the government will have to flesh out in regulations, Hani said. Questions of scope were just one area addressed in the technical corrections. The proposed IRS regulations "defined the phrase 'income, gain, loss, deduction, or credit' very broadly to include virtually everything under the sun, and so there was some question about whether they went too far in their authority" and whether that phrase "could really be defined as expansively as they did. Those questions are now moot because the statute now broadly defines partnership-related item," he said. In regards to appropriate netting, the corrections offer specificity as opposed to leaving the door open for the IRS and Treasury to decide which items can appropriately be netted together, "so the government can't pull apart taxpayer-favorable adjustments from government-favorable adjustments and group them separately, which has an advantage to the government," Hani said. The technical corrections also addressed the pushout election that many practitioners initially considered problematic. "Everyone recognized that as a problem with the statute when it was first released or enacted, but that was not something the IRS and Treasury could solve in regulations," Hani said. The way the statute was originally written made the pushout election less attractive, so this removes a barrier for partnerships wanting to choose that route, he said. The agency will have to revise the rules to reflect that the taxpayer can take into account both increases and decreases, "which will be a substantive change," Hani said, adding that it may not require the government to do a lot of rewriting, "but care should be taken to make sure nothing is missed that needs revising."