Page 47 - The TEFRA Partnership Audit Rules Repeal:
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What to consider now—sellers
Before 2018—elect in and shift risk to buyers?
• Ensure no push-out election, no indemnification, etc. After 2018
• Who controls push-out election for prior years?
− Could the seller remain the PR?
• Any liability to contribute if no push-out?
− Indemnification?
What happens if there is a termination?
• Example: one partner in two-person partnership sells interest to second partner; partnership agreement requires partnership to make payment under section 6226. Is seller potentially liable for tax?
Copyright © 2016 PricewaterhouseCoopers LLP. All rights reserved. Coming changes to IRS Audits of partnerships 38
