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TREAS/IRS | RIN: 1545-BO03 | Publication ID: Fall 2017 |
Title: ●Centralized Partnership Audit Regime--Section 6226 Elections With Pass-Through Partners | |
Abstract:
Section 6226, as amended by the Bipartisan Budget Act of 2015, Pub. L. 114-74 (the BBA), provides a partnership may elect to push out the partnership adjustments made by the service in lieu of paying the imputed underpayment determined under section 6225. The proposed regulations issued on June 14, 2017, reserved on the issue of how this election applies if the partnership making the election under section 6226 has pass-through entities as partners. These proposed regulations provide rules addressing how pass-through partners take into account adjustments reflected on a statement furnished to the pass-through partner under proposed 301.6226-2. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: First time published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
EO 13771 Designation: Deregulatory | |
CFR Citation: 26 CFR 301 | |
Legal Authority: 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-120233-17 (NPRM) Drafting attorney: Jennifer Black (202) 317-5216 Reviewing attorney: Gregory Armstrong (202) 317-5131 Treasury attorney: Brendan O'Dell (202) 622-1868 CC: PA:07 | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: Businesses | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Jennifer Black Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-5216 Email: jennifer.m.black@irscounsel.treas.gov |