Key takeaways

• The Treasury Department and the IRS published proposed regulations today under the partnership audit regime. The proposed regulations are almost identical to those released in January.
• The proposed regulations continue to reserve on the ability for the push out election to be used in tiered partnerships, but Treasury intends to publish additional regulations with an approach on the issue. The proposed regulations made no changes to the roundly criticized partnership representative rules.
• Partnership agreements should be drafted with these rules in mind.