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Bloomberg BNA Quotes Charles Ruchelman on New Partnership Examination and Collection Laws

April 22, 2016, Bloomberg BNA

Bloomberg BNA quotes Charles M. Ruchelman during an April 21st webinar regarding the new partnership audit laws, which allow a partnership to opt-out of the new regime for partnerships who furnish no more than 100 statements to its partners. For the full article, please visit the Bloomberg BNA's website (subscription required).

Excerpt taken from the article.

Regulatory Health Risk

This limit is giving some people “heartburn,” Charles Ruchelman, a member at Caplin & Drysdale Chartered, said. He notes that the Joint Committee on Taxation's Bluebook, includes examples that would allow partnerships with disregarded entities to opt out of the rules (50 DTR G-2, 3/15/16).

It raises the question if “there is any room there to disregard the disregarded entity in terms of counting the number of partners for the 100 or fewer partner [requirement],” Ruchelman said.

. . .

Leniency Likelihood

Ruchelman asked if partnerships that elect out will still be eligible to file an administrative adjustment request (AAR).  Right now the statute seems to be written in a way that would not allow an AAR option where there has been an opt-out of the regime.


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