Skip to Main Content
 

Bloomberg BNA Quotes Charles Ruchelman on New Partnership Examination and Collection Laws

April 22, 2016, Bloomberg BNA

Bloomberg BNA quotes Charles M. Ruchelman during an April 21st webinar regarding the new partnership audit laws, which allow a partnership to opt-out of the new regime for partnerships who furnish no more than 100 statements to its partners. For the full article, please visit the Bloomberg BNA's website (subscription required).

Excerpt taken from the article.

Regulatory Health Risk


This limit is giving some people “heartburn,” Charles Ruchelman, a member at Caplin & Drysdale Chartered, said. He notes that the Joint Committee on Taxation's Bluebook, includes examples that would allow partnerships with disregarded entities to opt out of the rules (50 DTR G-2, 3/15/16).

It raises the question if “there is any room there to disregard the disregarded entity in terms of counting the number of partners for the 100 or fewer partner [requirement],” Ruchelman said.

. . .

Leniency Likelihood

Ruchelman asked if partnerships that elect out will still be eligible to file an administrative adjustment request (AAR).  Right now the statute seems to be written in a way that would not allow an AAR option where there has been an opt-out of the regime.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)