ADMINISTRATIVE

Rev. Rul. 2019–05, page 766. Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the calendar quarter beginning April 1, 2019, will be 6 percent for overpayments (5 percent in the case of a corporation), 6 percent for underpayments, and 8 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 3.5 percent.

T.D. 9844, page 781. These final regulations provide rules implementing the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015, which was amended by the Tax Technical Corrections Act of 2018. These final regulations provide guidance on the scope of the regime, the requirement for consistent reporting, the calculation and modification of imputed underpayments, the push out election, administrative adjustment requests, notices, assessment, penalties, interest, judicial review, period of limitations, and definitions and special rules, including rules for coordination with chapters 2, 2A, 3, and 4.