Family Office Elite Spring_16

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3. Modify “Imputed Underpayment” Where Reviewed Year Partner Files Amended Reviewed Year Tax Return: Third, a partnership can reduce the amount of the “imputed underpayment” if one or more of the “reviewed year” partners files an amended return and pays the tax attributable to the adjustment allocable to that partner. To implement this, the partnership must submit information to the IRS sufficient to modify the “imputed underpayment” amount within 270 days of the notice of proposed adjustment. Verifying that an amended tax return has been filed by a reviewed year partner may raise certain privacy concerns. A partnership thus may wish to establish a method that allows for the implementation of this alternative, rather than undergo the “imputed underpayment” procedure. IV. Powerful New Partnership Representative: The Code now mandates that the partnership designates a “partnership representative” instead of a “tax matters partner.” The “partnership representative” will “have sole authority to act on behalf of the partnership” and the “partnership and all partners shall be bound by actions taken … by the partnership.” Interestingly, this controlling entity need not be a partner in the partnership. Furthermore, the new rule significantly curtails the ability of other partners to participate in an IRS examination or litigation with the IRS. Therefore, partnership agreements may need to be adjusted to provide contract rights to other partners that once existed as a statutory matter under TEFRA. For example, a partnership might consider whether the Partnership Representative has unbridled power to settle a case or extend the statute of limitations without approval from the other partners. This new statutory regime obviates the need of the IRS to “chase down” each and every partner to sign a Form 870-PT (Agreement for Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts) or sign a Form 906 (Closing Agreement On Final Determination Covering Specific Matters) in order to implement an examination’s adjustments or a settlement. For present purposes, partnership agreements should be revised to reflect this new, critical designation. If there is no partnership designated representative, the Code gives the IRS the authority to designate one. Certainly, partnerships and partners do not want to relinquish that selection right to the IRS. These new rules apply to partnership tax years beginning after December 31, 2017. However, a partnership may elect to have the new rules apply to partnership tax years beginning after the date of enactment and before January 1, 2018. Given the many new legal terms and concepts, and the potentially significant shift of the benefits and burdens of post-adjustment tax items, existing partnerships and partners should review and modify their partnership agreements. New partnership agreements should accommodate the new partnership tax audit and collection regime. Charles M. Ruchelman is a Member of Caplin & Drysdale, a Washington, D.C.-based law firm. cruchelman@capdale.com / 202.862.7834 31 FAMILY OFFICE ELITE MAGAZINE
Sub‐Saharan Africa Islamic Finance Convenon a Kampala Serena Hotel, Uganda Media Partner Africa’s New Momentum Affiliate Partners To become a Partner at this major International Conference, please contact our Strategic Partnerships team Yasmeen Shah on E: yasmeenshah@ethicolive.com T: +91 124 418 2794/95 M: +91 9899000538 in collaboration between www.ethicolive.com/events/uganda/ Ethico Live Limited is a UK registered company with its corporate headquarters at 2-4 Blythswood Square, Glasgow G2 4AD, UK. Through our on-the-ground presence in key centres across the world we are able to serve our clients in the global financial markets with high-profile international conferences in Europe, the Middle East, Africa and Asia.
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