The IRS proposed Friday, Nov. 20, guidance on when the new centralized partnership audit regime does not apply to certain partnership-related items.
The proposed regulations (REG-123652-18) provide that the centralized audit regime may not apply when an adjustment during the examination of a person other than the partnership requires a change to a partnership-related item.
The regulations also say that a partnership with a qualified Subchapter S subsidiary partner cannot elect out of the centralized partnership audit regime. Learn more.