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Legal Update

Treasury and IRS Announce Proposed Regulations on Implementation of New Centralized Partnership Audit Regime

6 February 2017
Mayer Brown Legal Update
The increasing use of partnerships has posed administrative challenges for the Internal Revenue Service (“IRS”). In an attempt to combat these challenges, Congress enacted section 1101 of the Bipartisan Budget Act of 2015 (“BBA”), which repealed longstanding TEFRA audit rules for partnerships and replaced them with a new centralized partnership audit regime. On January 18, 2017, the US Treasury Department and the IRS announced proposed regulations to address the implementation of section 1101. This Legal Update offers an overview of the key changes to the partnership audit rules introduced in the BBA, summarizes the most significant procedural elements of the proposed regulations, and presents critical considerations for taxpayers to bear in mind as the new regime unfolds.


  • Jeffrey M. Bruns
    T +1 312 701 8793
  • Matthew A. McDonald
    T +1 312 701 8321
  • Shawn R. O'Brien
    T +1 713 238 2848
  • William A. Schmalzl
    T +1 312 701 7225
  • Scott M. Stewart
    T +1 312 701 7821
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