The Internal Revenue Service (“IRS”) re-released the proposed new partnership audit rules and guidance. The IRS originally issued these proposed regulations on January 18, 2017 and withdrew them on January 20, 2017, only to reissue them on June 13, 2017. These new rules are effective for partnerships with tax years beginning after December 31, 2017, as outlined in our prior newsletter The New Partnership Tax Audit Rules: Are You Prepared for Change in 2018?
The newly released, re-issued regulations contain two minor changes: (1) the removal of an example dealing with the netting of income and depreciation expense, and (2) an expanded section about allowing tiered partnerships to pass through certain adjustments to individual partners. The balance of the re-issued regulations remain intact similar to the version issued in January 2017.