Overview
Alysse McLoughlin addressed the IRS authority to expand the types of partners that are eligible toelect out of the new partnership audit regime, saying that disregarded entities are an obvious candidate for becoming eligible for this election because the disregarded entity has to be looked through when determining whether the owner is an eligible partner for electing out. “I think that’s an easy one to add at some point” in the final regs, Ms. McLoughlin added.