188bet亚洲真人体育下载 Calls for More Clarity and Revisions to Proposed Regulations on Centralized Partnership 审计 Regime at IRS Hearing

莎拉·艾伦·安东尼，188bet亚洲真人体育下载网址，是 美国注册188bet亚洲真人体育下载 (188bet亚洲真人体育下载) Partnership 税 Technical Resource Panel, 作证 at an Internal Revenue Service (IRS) hearing on September 18 about regulations that were proposed earlier this year to implement the Centralized Partnership 审计 Regime.

Allen-Anthony, Crowe Horwath LLP的税务高级经理, emphasized that the Centralized Partnership 审计 Regime (Regime) significantly changes the way adjustments made by the IRS during an examination are accounted for by a partnership.  “A bedrock principle of partnership taxation is that all items of income and expense flow through to the partnership’s owners, 包括与国税局审计有关的调整,艾伦-安东尼说.  “The Regime replaces this long-standing method with one where the default mechanism requires the partnership to pay any additional tax due, resulting in significant administrative and accounting complexities.”

Allen-Anthony’s testimony focused on the 188bet亚洲真人体育下载’s recommendations and concerns about the “push-out” process for tiered partnership structures, 对合伙人资本账户和基础的影响, the process for designating the partnership representative and allowing an audited partnership access to the IRS Office of Appeals.

“We propose that the IRS establish procedures to allow for the push-out of audit adjustments through a tiered partnership structure,艾伦-安东尼作证说.  “In general we discourage establishing any limitations on tiers, 金额, 合作伙伴数量, or other attributes because those limitations may result in the partners paying inappropriate amounts of tax,”她说。.

“One of the main areas of increased complexity involves the effect of audit adjustments on each partner’s capital account and partnership basis,根据艾伦-安东尼的证词.  She presented the 188bet亚洲真人体育下载’s proposals designed to simplify that process while maintaining the core principles of partnership accounting.

Regarding the Regime’s proposed procedures for designating and replacing a partnership representative, Allen-Anthony 说 the 188bet亚洲真人体育下载 opposes the proposed procedures for appointing a “designated individual” to act on behalf of an “entity partnership representative;” recommends allowing a partnership to revoke and replace their partnership representative at any time and that a partnership representative should have the ability to resign at any time; opposes the Regime’s provision that allows a resigning partnership representative to appoint their own successor, and recommends that the IRS clarify that all partnerships be required to appoint a partnership representative on their timely filed tax return in order to protect the interests of both the IRS and the partnership.

Allen-Anthony noted that the Regime does not include a reference to an audited partnership’s right to challenge various determinations under the Regime with the IRS Office of Appeals.  She described the appeals process as a “vital option for taxpayers to resolve an issue without having to go 税 Court.”  Allen-Anthony cited five specific situations under which partnerships should have the right to challenge actions or determinations by the IRS via the appeals process.

乔纳森角, 188bet亚洲真人体育下载网址, CGMA, 美国注册188bet亚洲真人体育下载税收政策和倡导高级经理, 报道称，美国注册188bet亚洲真人体育下载提交了一份更广泛的 评论信 about the Regime on August 14 and recommended a one-year delay in implementation of the Regime in a 信 6月13日.  角, who serves as staff liaison on the partnership issue, 说, “The 188bet亚洲真人体育下载 will continue to work closely with the IRS, Congress and other stakeholders in developing the most effective and efficient ways to implement this new Regime.”

看 video 艾伦-安东尼和霍恩讨论听证会的视频.