Following Congress’ enactment of a new set of rules for partnership tax audits for 2018 and thereafter, the US Internal Revenue Service (the “IRS”) released 277 pages of proposed regulations and accompanying explanations to implement this new regime. Although President Trump’s moratorium has temporarily frozen action on these regulations, the IRS has stated that it is a priority to release and finalize these rules. Mark Leeds, of Mayer Brown’s New York office, has prepared the attached detailed explanation of the proposed regulations and provides agreement provisions that partnerships and entities taxed as partnerships should consider for these years.