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Final regulations: Election out of centralized partnership audit regime

U.S. final regulations

The U.S. Treasury Department and IRS today released an advance version of final regulations (T.D. 9829) concerning the rules and procedures for electing out of the centralized partnership audit regime.


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The purpose of this report is to provide text of today's final regulations [PDF 264 KB].


The preamble explains that today's release finalizes regulations that were proposed in June 2017 but with certain amendments made in response to comments received. The preamble to the final regulations describes and addresses such comments in three general areas:

  • Determining the number of partners of the partnership for purposes of determining whether the partnership has 100 or fewer partners under section 6221(b)
  • Determining what partners constitute eligible partners for purposes of determining whether the partnership is an eligible partnership under section 6221(b)
  • The mechanics of making the election under section 6221(b)

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