Partnership/RAR Work Group

Partnership/RAR Project 
Reference Information

Agendas, working documents, and other project-related information from previous meetings:

• Proposed Model RAR Statute incorporating changes discussed at Uniformity Committee meeting 7/2018
• Minnesota Comments on Model Uniform Reporting Statute
• Letter from ABA supporting approval of the Model Uniform Reporting Statute
• Letter from Master Limited Partnership Association endorsing the proposed Model RAR Statute
• TEI's Endorsement of the Model Uniform Statute and Regulation for Reporting Adjustments to Federal Taxable Income and Federal Partnership Items as of July 18, 2018
• AICPA Position Paper on State Partnership Audits
  • AICPA one-pager: State Conformity to Federal Partnership Audit Rules
• Letter from COST endorsing the proposed Model RAR statutePartnership Work Group Staff Report - Comment - July 9, 2018
• Proposed Model RAR Statute - Interested Parties Version Incorporating Changes Related to Partnership Pays Election And Including Other Edits and Comments Throughout as of 6/27/18
• Proposed Model RAR Statute - Interested Parties Version (with MTC staff edits 6-27-18)
• Proposed Model RAR Statute - Interested Parties Version as of 6-25-18 (with MTC staff edits 6-25-18)
• Proposed Model RAR Statute - Interested Parties Version as of 4-27-18 (with MTC staff edits 4-4-18)
• Proposed Model RAR Statute - Interested Parties Version as of 4-27-18 (with MTC staff edits 4-4-18) - REDLINE version
• Partnership Pays - Investment Income Option for review
• Partnership Pays - Nexus Issue proposals
• Partnership Work Group Staff Report - 6-18-18
• Discussion Draft - Antiabuse Provision
• Partnership Work Group Staff Report - 4-3-18
• Proposed Model RAR Statute - Interested Parties Version 5.1 as of 3-7-18 (with MTC staff edits 1-23-18)
• Proposed Model RAR Statute - Interested Parties Version 5.1 as of 1-3-18 (with MTC staff edits 1-23-18)
• Partnership Work Group Staff Report, Jan. 11, 2018
• Proposed Model RAR Statute - Interested Parties' Version of MTC Draft, January 3, 2018
  • Proposed Model RAR Statute - Interested Parties' Version of MTC draft (REDLINED)
• Proposed Model RAR Statute - Interested Parties' Version of MTC Draft, December 20, 2017
  • Proposed Model RAR Statute - Interested Parties' Version of MTC draft (REDLINED)
• Explanation of Key Modifications to MTC Draft by Interested Parties, December 20, 2017
• Partnership Work Group Staff Report, October 25 2017
  • Partnership Model - Attachment A (As Proposed by Interested Parties)
  • Partnership Model - Attachment B (Changes and Comments)
  • Partnership Model - Attachment C (Changes Accepted - Clean)
• Draft version of Model Conformity/RAR Act - Revised Draft (Version #3) Submitted for Consideration on September 27, 2017
  • Redline of Revised Draft (Version #3)
• Partnership Work Group Staff Report
• Draft version of Model Conformity/RAR Act - Revised Draft (Version #2) Submitted for Consideration on July 5, 2017
  • Redline of Revised Draft (Version #2)
• Draft version of Model Conformity/RAR Act
• Presentation of draft version of Model Conformity/RAR Act by interested parties [Link will open in PPT]
• Partnership Work Group Staff Report, May 18, 2017
• Interactive Slides Illustrating Partnership Audit Rules (PowerPoint)
• Partnership Presentation to Uniformity Committee - 3/8/17
• Evaluation of the “Push-Out” Election in its Current Form
• Report on federal changes to partnership rules – Bruce Fort, MTC, December 10, 2015
  • Pennsylvania entity level taxation structure

Materials related to federal legislative revisions to the partnership audit regime:

• GAO Report: With Growing Number of Partnerships, IRS Needs to Improve Audit Efficiency
• IRC Partnership Audit and Adjustment Provisions Effective after 12-31-17
• IRC Partnership Audit and Adjustment Provisions Effective after 12-31-17 with proposed tech corrections
• Joint Committee Analysis of Technical Corrections Bill
• Technical Corrections Bill - HR 6439
• AICPA Comments to Congress on Proposed Legislative Revisions to the Partnership Audit Regime
• Joint Committee - BBA Blue Book
• Bipartisan Budget Act of 2015

Proposal from ABA/AICPA Task Force for Uniform Model RAR Statute

• Draft ABA-AICPA Checklist for Partnership Conformity 1-27-17
• ABA Comments
• AICPA position paper: Reporting to State Tax Authorities of Federal Tax Examination Adjustments and Their Effect on State Tax Liability
• AICPA Letter to MTC re: Position Paper, dated 3/1/2017
• TEI State and Local Tax Policy Statement
• 2016 Survey – Reportable Adjustments
• Proposed Amended RAR Draft
• Letter from COST, TEI, the ABA SALT Committee, and the AICPA State Tax Working Group
• Proposed Model Report of Federal Audit Changes developed by Tax Executives Institute
• COST Policy Statement

Other relevant publications:

• AICPA - New TQA on tax accounting considerations under the partnership audit regime
• Joint Committee on Taxation technical explanation of revenue provisions 
• Eileen Reichenberg Sherr & Steven N.J. Wlodychak, State Challenges With the New Federal Partnership Audit Rules
• Marianne Evans, Dan De Jong, Shirley K. Sicilian, & Julia Flanagan, New Federal Partnership Audit Rules Create State Tax Issues
• Bruce P. Ely, Christopher R. Grissom & William T. Thistle, Blurred Lines: State Taxation of Nonresident Partners
• Partnerships & Partners: Who and How Much? 
• New Partnership Audit Rules - Part 1
• New Partnership Audit Rules - Part 2
• “Business in the United States: Who Owns It and How Much Tax do They Pay?” - NYU School of Law Colloquium on Tax Policy and Public Finance
• Office of Tax Analysis: Business in the United States: Who Owns it and How Much Tax Do They Pay?
• Office of Tax Analysis: Methodology to Identify Small Businesses and Their Owners