08/07/2017
NAREIT is requesting clarification on proposed Treasury regulations (REG-136118-15) released in connection with the partnership audit rules enacted as part of the Bipartisan Budget Act of 2015.
In a letter sent to the IRS on Aug. 4, NAREIT noted that “certain procedural aspects of the section 6225(c) reduction that may be made in respect of a REIT partner’s deficiency dividends should be clarified to allow for extensions as a matter of course in certain situations and to resolve current ambiguities regarding when a ‘determination’ occurs for purposes of section 860.”
Additionally, the letter discussed the treatment of disregarded entities under the proposed regulations.
(Contact: Cathy Barre at cbarre@nareit.com)