Definition of New Partnership Audit Rules


New Partnership Audit Rules means the provisions of Subchapter C of Chapter 63 of the Code, as revised by Section 1101 of the 2015 Budget Act, as such provisions may thereafter be amended and including Treasury regulations or other guidance issued thereunder.
Sample 1

Examples of New Partnership Audit Rules in a sentence

The Company will not elect into application of the New Partnership Audit Rules under Section 1101(g)(4) of the 2015 Budget Act or any similar provision relating to the New Partnership Audit Rules.
The Tax Matters Member will, on a reasonably timely basis, provide the Company with copies of all notices received by the Tax Matters Member in connection with any proceeding or potential adjustment relating to the Company that is subject to the New Partnership Audit Rules.
If the Company comes to be subject to the New Partnership Audit Rules for any period, the Company's Partnership Representative for purposes of the New Partnership Audit Rules will be the Tax Matters Member.
With respect to any proceeding or potential adjustment subject to the New Partnership Audit Rules, the Tax Matters Member will, on a reasonably timely basis, provide each Member with copies of all notices received by the Company or the Tax Matters Member from the Internal Revenue Service.
In exercising its authority as Tax Matters Member under the New Partnership Audit Rules, the Tax Matters Member shall at times be subject to the direction of Administrative Member.