Tax Memo

Instructions

This case requires that each group operates in consulting mode, i.e., the skills to be developed herein involve observation and analytical thinking.  Some research activities might be involved, but the deliverable is not a tax return to be prepared.  As such, I will be looking for insights, points of view and advise on how partners and partnerships can effectively manage the impact of the provisions below.  I provided you the actual cite to the regulations,  the format is a  memo should  and should not be a recitation of the regulations (as I provided you with those) but rather it should contain an analysis of the implications for partnerships and partners of these rules with practical takeaways based on your analysis.  You may attach as exhibits to your memo, tax return disclosures examples, updates or other compliance related materials.  This assignment will be scored based on the quality of the content so please focus on providing insights, advice and takeaways in a consulting type approach. Partnership representative:  On August 6, 2018, Treasury and the IRS issued final regulations (TD 9839) regarding the authority, designation, and replacement of the partnership representative under the centralized partnership audit regime . The centralization of authority in the hands of a single partnership representative places a premium on identifying the appropriate person to serve as the partnership representative.  Please discuss the implications of these regulations.Please consider including commentary as to your view on whether these are "aggregate" or "entity"  based items and why.

Answer

Tax MemoTo: The PartnersFrom: {Insert name}Date: June 4, 2020RE: IRS Final Regulation (TD 9839)It is important to note that, as of August 6, 2018, new partnership taxable laws were introduced. The new taxation regulation replaced the TEFRA partnership audit rules, which have been in effect since 1982.TEFRA Partnership Audit RuleThe TEFRA partnership audit rule stipulated that a partnership representative or designated individual has an exclusive right to represent the partners and the partnership on partnership-related issues or resulting partnership tax controversy (PwC). The regulation had been in effect until December 2017, when the process of its replacement began.IRS Final Regulation (TD 9839)The IRS Final Regulation (TD 9839) became effective from August 6, 2018. The introduction of...
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