On January 1, 2018, new IRS regulations are set to go into effect which will have consequences for both limited liability companies (LLCs) and partnerships. A well-structured entity reaps many benefits — liability protection, tax savings and asset protection among them — so attention to the evolution of the new centralized partnership audit regime is critical.
The IRS’s re-released proposed regulations (REG-136118-15) will generally require partnerships or LLCs to pay any tax deficiency, penalty or interest — leaving many desiring to opt out when possible. In this second part of a series on the regulations, CGS3 partner and tax practice team chair Phil Jelsma discusses who is eligible to opt out of the centralized partnership audit regime according to the “100 partner rule” as well as how eligible partnerships and LLCs may make that election.
The remainder of the series will examine other aspects and consequences of the regulations in more detail, focusing on the role of the partnership representative, the consistency requirement and rules for filing an administrative adjustment request.
Read the full article from the San Diego Daily Transcript here.