188bet亚洲真人体育下载 Lays Out Recommendations to IRS Regarding Guidance to Implement New Centralized 伙伴关系 审计 Regime

的 美国注册188bet亚洲真人体育下载 (188bet亚洲真人体育下载) has submitted more than 40 specific recommendations to the Internal Revenue Service (IRS) to consider when drafting the necessary administrative guidance to implement the new partnership audit rules, 都是作为 2015年两党预算法案 and are generally effective for tax years 2018 and later.

的 188bet亚洲真人体育下载 explained in its October 7 信 that the 2015 Budget Act established a new centralized partnership audit regime (Regime), which will generally centralize the ability of the IRS to audit, assess and collect any determined underpayment of tax directly from a partnership, subject to certain available elections.  Those elections include allowing certain partnerships to opt-out of the Regime, as well as an election for partnerships to push-out the responsibility for payment of any assessment imposed to its partners.  实施制度, 美国注册188bet亚洲真人体育下载表示, will require balancing a simplified assessment and collection process imposed at the partnership level against the general expectation that tax is imposed only on the appropriate taxable individual or entity, only on the properly calculated amount of taxable income and only at the appropriate rate of tax as enacted in the applicable section of the Internal Revenue Code.

的 188bet亚洲真人体育下载 explained that its recommendations are focused on the new procedures that will occur prior to the commencement of an examination, between the time an assessment is proposed and made final by the examiner, as well as the determination of which individuals and entities are ultimately responsible for paying the appropriate share of an assessment.

具体地说, the 188bet亚洲真人体育下载 made recommendations covering issues related to the small partnership opt-out, selection of the 伙伴关系 Representative, calculation of the modified imputed underpayment, the election to push-out adjustments to the partners and filing Administrative Adjustment Requests with the IRS.  的 信 stated that the 188bet亚洲真人体育下载’s recommendations are designed to balance the IRS’s desire to simplify the assessment and collection of audit adjustments from complicated multi-tier partnership structures with the tax code’s basic principles of fairness and equity.

的 188bet亚洲真人体育下载 noted that a subsequent 信 will address a number of areas of concern regarding the impact of the new Regime on substantive Subchapter K tax issues related to Subchapter S corporations, as well as state level tax adjustments resulting from partnership audits under the Regime.

除了, the 188bet亚洲真人体育下载 wrote that it intends to submit a separate comment 信 to the appropriate congressional committees to identify areas where it believes legislative changes are required to facilitate the ability of the IRS to fairly and equitably administer the Regime.