Insights
Jim Malone Provides Comments for ABA Tax Section's Comment Letter to the IRS on Proposed Regulations as Part of the Bipartisan Budget Act of 2015
In a September 11, 2017 comment letter from the American Bar Association's (ABA) Section of Taxation to the Internal Revenue Service (IRS), Tax Controversy Principal James R. Malone, Jr. provided substantive comments regarding proposed regulations implementing the partnership audit procedures enacted as part of the Bipartisan Budget Act of 2015 (BBA).
The BBA adopted a new centralized regime through which the IRS will audit partnerships and repealed the partnership audit provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and electing large partnership (ELP) regimes. It replaced them with a new set of rules for partnership audits and judicial review of partnership audit adjustments. The ABA Section of Taxation's comment letter addresses the proposed regulations and offers recommendations for changes when those regulations are finalized.