George Hani was quoted regarding the guidance released by the Internal Revenue Service (IRS) that addresses the new partnership audit regime, which takes effect January 1, 2018. Under the new regime, a partnership is generally required to pay tax liabilities the year the IRS makes an adjustment unless the partnership elects to "push out" those liabilities to the members of the partnership during the year under review. A new term, "affected partner," is mentioned in the proposed regs, Hani said, adding that the term refers to an upper-level pass-through partner that receives a Section 6226 push-out statement from a lower-level partner. In previous guidance, there was only the "review year partners," which are partners of the entity in the year the IRS issues an adjustment, and "adjustment year partners," which are partners at the business entity at the time of the year under review, he said. There is a question of whether upper-level partnerships would have enough time to meet the requirements of the proposed rules if the lower-level entity delays its push-out election, Hani said, adding that under the guidance, any upper-level partnerships affected by a push-out must issue its own statements by the lower-level partnership's initial deadline. Applying the original partnership due date to the other partnerships makes sense on an administrative level because otherwise there could be a perpetual statement-issuing process if every upper-tiered entity were given more time to issue their own statements, he said.