Page 345 - International Taxation IRS Training Guides

Intersecting Tax Law Changes

TCJA provisions, other tax
 In addition to international

have recently been enacted and
law changes
implemented

 Centralized partnership audit regime

• Enacted as part of
Bipartisan Budget Act of 2015 and corrected and
subsequent act
amended by

TEFRA and electing large partnership audit procedures
• Replaces
and litigation rules

• Generally
provides that any IRS tax adjustments resulting will be
the partnership level, rather than the
determined and collected at
partner level

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