Internal Revenue Service November 24, 2020 – Federal Register Recent Federal Regulation Documents

Treatment of Special Enforcement Matters
Document Number: 2020-25904
Type: Proposed Rule
Date: 2020-11-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations to except certain partnership-related items from the centralized partnership audit regime that was created by the Bipartisan Budget Act of 2015, and sets forth alternative rules that will apply. The centralized partnership audit regime does not apply to a partnership-related item if the item involves a special enforcement matter described in these regulations. Additionally, these regulations propose changes to the regulations to account for changes to the Internal Revenue Code (Code). Finally, these proposed regulations also make related and clarifying amendments to the final regulations under the centralized partnership audit regime. The proposed regulations would affect partnerships and partners to whom special enforcement matters apply.