188bet亚洲真人体育下载 Recommends Maximum Flexibility for Centralized Partnership 审计 注册ime 注册ulations

的 美国注册188bet亚洲真人体育下载 (188bet亚洲真人体育下载) has recommended to the Internal Revenue Service (IRS) that proposed regulations regarding the Centralized Partnership 审计 注册ime should provide maximum flexibility in adjusting the tax attributes of an audited partnership and its partners, 包括一个选择性的简化程序.

国税局的拟议规定, 二月二日发行, 2018, provide rules addressing how and when partnerships and their partners adjust tax attributes to reflect audit adjustments under Internal Revenue Code (IRC) section 6225 of the Centralized Partnership 审计 注册ime.

在5月16日 信, the 188bet亚洲真人体育下载 explained that under the Centralized Partnership 审计 注册ime a partnership generally is liable for the net increase in tax, “推定的少付”,” resulting from adjustments to items of income, 获得, 损失, 扣除, or credit of a partnership during the year under audit.  根据拟议的条例, when a partnership pays the imputed underpayment under the rules of IRC section 6225, an exclusive list of tax attributes requires adjustment for adjustment year partners.  税 attributes are defined as “the tax basis and book value of a partnership’s property, 根据IRC第704(c)条确定的金额, adjustment year partners’ bases in their partnership interests, and adjustment year partners’ capital accounts determined and maintained in accordance with section 1.704-1(b)(2).

的 188bet亚洲真人体育下载 made the following recommendations related to the proposed regulations:

1. Provide a flexible procedure for applying audit adjustments to the tax attributes of audited partnerships and their partners.
2. Provide audited partnerships an elective “simplified tax attribute adjustment procedure” (STAAP) under certain conditions.  Only partnerships that accept limitations on the type of section 6225 modifications that could reduce their imputed underpayment would qualify for the STAAP.
3. Provide audited partnerships an elective “enhanced STAAP” which would expand the types of section 6225 modifications allowed.  Only audits resulting in proposed imputed underpayments (before any modifications) below a threshold amount would qualify for the enhanced STAAP.
4. Allow an allocation of an adjustment to property of similar character following the allocation rules set forth in Treas. 注册. § 1.755-1(c) in cases where adjustments apply to specified tax attributes of partnership property held in the reviewed year, 但不再在调整年度举行.
5. Allow any reasonable method of applying successor rules for mergers and divisions occurring between the reviewed year and the adjustment year.
6. Treat the remittance by a former partner to the partnership under a reimbursement or indemnification agreement of an allocable share of tax, interest and penalties paid by the partnership under section 6225 as a tax-free receipt by the partnership; reduce the partnership’s section 705(a)(2)(B) expense by the amount of the payment and allocate that reduction in full to the former partner’s successor; and provide that the payment by the former partner is treated as a nondeductible expense by that partner.

的 188bet亚洲真人体育下载 provided an analysis for each of its six recommendations.  Examples were included for some of the recommendations.