United States:
New Final Partnership Audit Regulations
19 February 2019
Ropes & Gray LLP
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On December 21, 2018, IRS and Treasury issued final regulations
implementing the partnership audit regime (T.D. 9844). The final regulations largely
adopt, with some changes, the proposed regulations issued in August
2018. By issuing almost 200 pages of preamble, the final
regulations provide extensive discussion of which comments were
incorporated and why others were not. Likely, IRS is thinking
ahead to litigation over the validity of the regulations by issuing
such broad discussions of the comment process. The most
significant changes to the proposed regulations are changes to the
definition of partnership-related items and changes allowing
administrative adjustment of partnership-related items.
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