Treasury, IRS Issue Proposed Regulations on Centralized Partnership Audit Regime: Today, Treasury and the IRS issued proposed regulations (REG-118067-17) to implement the centralized partnership audit regime. The regulations address how and when partnerships and their partners adjust certain tax attributes to take into account partnership adjustments under both section 6225 (relating to the calculation of the imputed underpayment) and section 6226 (which provides for an alternative to payment of the imputed underpayment via the so-called “push-out” election). More specifically, the regulations propose special allocation, inside basis adjustment, outside basis adjustment, and capital account adjustment rules for imputed underpayments (including adjustments thereto) and the results of push-out elections. The new regulations supplement and amend proposed regulations (REG-136118-15) released in June 2017.
DOJ Settles Z Street Lawsuit Involving IRS Viewpoint Discrimination: Today, the Department of Justice (DOJ) announced that it has entered into a settlement with Z Street, pending approval by the U.S. District Court for the District of Columbia. Z Street, a pro-Israel group, alleged that the IRS applied heightened scrutiny to applications for tax-exempt status received from organizations connected in any way to Israel, including Z Street’s, resulting in a delay to the processing of Z Street’s application for tax-exempt status. According to a DOJ press release, the settlement agreement includes an apology from the IRS to Z Street for the delayed processing. A copy of the proposed consent order can be accessed here.
EU Launches Blockchain Observatory and Forum: Today, the European Commission launched the European Union (EU) Blockchain Observatory and Forum to “highlight key developments of the blockchain technology, promote European actors and reinforce European engagement with multiple stakeholders involved in blockchain activities.”