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Marc Gerson and George Hani Comment on Technical Corrections to New Partnership Audit Regime in Bloomberg BNA

Subtitle
"Tax Extenders Bill: Last Hope for Partnership Audit Corrections?"

Bloomberg BNA

Firm Chair Marc Gerson and Tax Department Chair George Hani commented on the potential for technical corrections to the new partnership audit regime in the form of an extenders bill. The possibility that Congress will enact technical corrections before the centralized audit regime takes effect Jan. 1 depends on whether another vehicle besides tax reform moves this year, Gerson said. "Technical corrections because they do not by definition have a revenue impact cannot be included as part of the reconciliation bill being used for tax reform so another vehicle is necessary," he said. "The pace at which tax reform is going and the all-consuming energy that it's attracting make it unlikely that you'll see an extenders bill before year-end," Hani said, adding that it may be more likely that an extenders bill is enacted retroactively after the start of 2018. "Congress has shown in the past that they're willing to pass extenders after the fact, so maybe there's a chance for something come the new year." Another possibility for retroactive technical corrections to the BBA would be including them in corrections to the tax reform bill if it's enacted, he said.