Page 45 - The TEFRA Partnership Audit Rules Repeal:
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Considerations for tax-exempts
Any possibility that partnership could be required to pay an entity-level tax?
Can tax expense be allocated entirely to taxable partners?
What if taxable partners have insufficient section 704(b) capital to “absorb” the nondeductible tax expense?
Who bears cost of any tax distributions?
Would special allocations to address UBTI/ECI apply to adjustments to income?
Copyright © 2016 PricewaterhouseCoopers LLP. All rights reserved. Coming changes to IRS Audits of partnerships 36
