Daily Tax Update - March 4, 2016: IRS Requests Comments on Implementation of New Partnership Audit Regime

IRS Requests Comments on Implementation of New Partnership Audit Regime:  Today, the IRS issued Notice 2016-23, which solicits comments on the new partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (BBA).  Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level.  The new partnership audit rules are generally effective for tax years beginning after December 31, 2017, although some partnerships may elect into the regime prior to that date.  This notice requests comments from the public to help implement these new rules and to assist in the guidance process.  Comments are requested by April 15.

IRS Updates Guidance on Industry Issue Resolution Program:  Today, the IRS issued Revenue Procedure 2016-19, which describes procedures for taxpayers and other entities under the jurisdiction of the Large Business and International (LB&I), Small Business and Self Employed (SB/SE), and Tax Exempt and Government Entities (TE/GE) Operating Divisions to submit issues for consideration under the IRS’s Industry Issue Resolution (IIR) program.  The objective of the IIR program is to identify and resolve frequently disputed or burdensome tax issues that are common to a significant number of entities.  This revenue procedure supersedes Revenue Procedure 2003-36 and expands the availability of the IIR program to issues with respect to entities under the jurisdiction of the TE/GE Operating Division.   In addition, the revenue procedure updates, revises and clarifies the procedures for submitting issues for consideration under the IIR program.