Final regulations centralized partnership audit regime | KPMG | GLOBAL

Final regulations: Election out of centralized partnership audit regime

U.S. final regulations

The U.S. Treasury Department and IRS today released an advance version of final regulations (T.D. 9829) concerning the rules and procedures for electing out of the centralized partnership audit regime.

1000

Related content

The purpose of this report is to provide text of today's final regulations [PDF 264 KB].

 

The preamble explains that today's release finalizes regulations that were proposed in June 2017 but with certain amendments made in response to comments received. The preamble to the final regulations describes and addresses such comments in three general areas:

  • Determining the number of partners of the partnership for purposes of determining whether the partnership has 100 or fewer partners under section 6221(b)
  • Determining what partners constitute eligible partners for purposes of determining whether the partnership is an eligible partnership under section 6221(b)
  • The mechanics of making the election under section 6221(b)

© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Request for proposal

 

Submit