New Audit Rules Preserve Sub K Intent, But Raise Questions

David Sherwood welcomed new IRS guidance on implementing the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA). “The new proposed regulations are a welcome explanation of the collateral consequences of imputed underpayments under the BBA,” Mr. Sherwood said, adding that “the new rules are complicated, but there was no way to avoid this given the structure of the BBA.”