New Partnership Audit Rules definition

New Partnership Audit Rules means the provisions of subchapter C of chapter 63 of subtitle F of the Code (i.e., Sections 6221 through 6241 of the Code), as in effect for tax years beginning after December 31, 2017, and any Treasury Regulations promulgated thereunder.
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New Partnership Audit Rules has the meaning set forth in Section 6.6.
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Examples of New Partnership Audit Rules in a sentence

  • Understanding the New Partnership Audit Rules ..........................

  • New Partnership Audit Rules ProjectThe Bipartisan Budget Act of 2015 (Pub.

  • Smith, Norton Rose Fulbright • Taxation by Executive Fiat: IRS Launches Renewed Attack on Valuation of Family Businesses – A Seismic Shift For Estate and Gift TaxationsNorm Lofgren, Gray Reed & McGraw, P.C. • Electing Into New Partnership Audit Rules Chester Grudzinski, Kelly, Hart & Hallman LLP Jason Hendrix, Kelly, Hart & Hallman LLP • Preparing for a Partial Plan Termination – Considerations and Consequences Jessica Stricklin, Baker Botts L.L.P. • Estate of Clara M.

  • This cooperation shall include making available to the Tax Matters Representative such personal information of the Member (including confidential tax information) as may reasonably be deemed necessary by the Tax Matters Representative in connection with the audit and subsequent administrative and judicial proceedings under the New Partnership Audit Rules.

  • The following subsections discuss the discretization of the operator D(u) in (39).3.1. Discretization of D1(u).

  • Since the Company is treated as a “partnership” for federal income tax purposes, the New Partnership Audit Rules apply to the Company.

  • Jim Nitsche, New Partnership Audit Rules Will Require Changes to Existing Partnership Agreements, LBA Bar Briefs (Oct.

  • If the Company is otherwise eligible, the Company shall, if approved by the Required Majority, file a timely annual election in connection with the filing of its tax return to have the Company opt out of the New Partnership Audit Rules in the manner provided in Code § 6221(b).

  • Some analysts have questioned whether the purposes for which FMF and Section 1206 can be used are as different as described by DOD.

  • BryantThe Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such audits.This article provides a brief summary of certain aspects of the New Partnership Audit Rules and also raises a few related issues to be considered by partnerships, partners and prospective investors in partnerships.

Related to New Partnership Audit Rules

  • BBA Partnership Audit Rules means Sections 6221 through 6241 of the Code, and any regulations promulgated or proposed under any such Sections and any administrative guidance with respect thereto.

  • Partnership Tax Audit Rules means Sections 6221 through 6241 of the Code, together with any final or temporary Treasury Regulations, Revenue Rulings and case law interpreting Sections 6221 through 6241 of the Code (and any analogous provision of state or local tax Law).

  • MLP Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the MLP, as amended or restated from time to time.

  • Partnership Act means the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. §§ 17-101, et seq., as it may be amended from time to time, and any successor to such statute.

  • SIFT Rules means the provisions of the Tax Act, including those contained in sections 104, 122 and 122.1 of the Tax Act, which apply to the taxation of a “specified investment flow through trust” and its unitholders.

  • Operating Partnership Agreement means the Fifth Amended and Restated Agreement of Limited Partnership of the Operating Partnership, as it may be amended, supplemented or restated from time to time.

  • Limited Partnership Agreement means the Second Amended and Restated Agreement of Limited Partnership of the Partnership dated as of March 9, 2004, as amended from time to time.

  • Partnership at will means a partnership in which the partners have not agreed to remain partners until the expiration of a definite term or the completion of a particular undertaking.

  • Public-private partnership agreement means an agreement

  • Partnership Representative has the meaning set forth in Section 5.2(a).

  • Borrower Partnership Agreement means the Limited Partnership Agreement of the Borrower dated as of January 17, 2014 as such agreement may be amended, restated, modified or supplemented from time to time with the consent of the Administrative Agent or as permitted under Section 10.10.

  • General Partner has the meaning set forth in the Preamble.

  • Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Operating Partnership dated as of , 2011, as the same may be amended, modified or restated from time to time.

  • Tax Matters Partner has the meaning set forth in Section 5.08.

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • 1940 Act Rules and Regulations means the rules and regulations of the Commission under the 1940 Act.

  • Delaware LP Act means the Delaware Revised Uniform Limited Partnership Act.

  • Advisers Act Rules and Regulations means the rules and regulations of the Commission under the Advisers Act.

  • Organizational Limited Partner means Xxxxx X. Xxxxxxx.

  • SAP Partner Code of Conduct means SAP Group’s global policy document that provides a set of informative guidelines to enable partners to comply with good business practices which is published on SAP’s partner-dedicated website.

  • Original Partnership Agreement has the meaning set forth in the recitals to this Agreement.

  • Apprenticeship Agreement means a written agreement between the Company and the person employed as an apprentice, and his/her parent or guardian if he/she is a minor, which agreement or indenture shall be reviewed by the Joint Apprenticeship Committee, approved by the Supervisor of Apprentices and registered with the Registration Agency.

  • Certificate of Limited Partnership means the Certificate of Limited Partnership of the Partnership filed with the Secretary of State of the State of Delaware as referenced in Section 7.2, as such Certificate of Limited Partnership may be amended, supplemented or restated from time to time.

  • Foreign limited liability limited partnership means a foreign limited partnership whose general partners have limited liability for the obligations of the foreign limited partnership under a provision similar to section 488.404, subsection 3.

  • PPB Rules means the rules of the Procurement Policy Board as set forth in Title 9 of the Rules of the City of New York (“RCNY”), § 1-01 et seq.

  • Company LLC Agreement means the Second Amended and Restated Limited Liability Company Agreement of the Company, dated as of May 25, 2011, as amended from time to time.