Lee Meyercord Quoted in Tax Notes Today on Audit Regulations

“Final Partnership Audit Regs May Provide Disregarded Entity Fix”

The final partnership audit regulations might revisit the definition of a passthrough partner to address an issue with disregarded entities.

…However, Lee Meyercord of Thompson & Knight LLP said it’s not clear whether a partner that holds its partnership interest through a disregarded entity can file an amended return. She said that such partners don’t qualify as indirect partners under the proposed regs because an indirect partner is defined as a partner that holds its interest though a passthrough partnership, and disregarded entities are specifically excluded from the definition of a passthrough partner.