There have been delays in getting child tax credits to entitled taxpayers, for example, because the IRS lacks the resources to quickly process them. Warner said he has been closely tracking implementation of state and local aid to make sure some unusual quirks in Virginia’s local governance structure don’t affect their payouts. Democrats and allied groups are encouraged by the Biden administration’s experience. The Cabinet is stocked with former mayors and governors who have dealt with these issues firsthand, as well as many veterans of prior administrations like White House chief of staff Ron Klain, who was Biden's chief of staff when Biden was vice president. “It’s details where you always find the devil,” said Sen. John Hickenlooper, D-Colo., who served two terms as governor of his state and two terms as the mayor of Denver before being elected to Congress in 2020. “Obviously, with any large investment in infrastructure and a recovery plan, there are going to be places where you encounter the unexpected. And I will say that I’m impressed by the quality of the staff that are working on those issues.” A cautionary tale is the 2009 stimulus, whose spending initiatives Biden oversaw as vice president. Then-President Barack Obama promoted the bill as being full of "shovel ready" projects that could quickly get people working. But investments in ambitious initiatives like high-speed rail failed to get past opposition from Republican governors, who killed transportation projects in Florida and New Jersey. Cost overruns derailed projects in Democratic states like California, where a plan to connect San Francisco to Los Angeles is stuck on more modest Central Valley line additions that are still in progress. Many voters didn't immediately see or feel the benefits of the legislation, even as supporters now credit the clean-energy incentives with boosting the solar and wind industries and the mix of tax breaks and infrastructure projects with staving off a more severe recession. The Biden administration has some advantages that Obama didn’t. A big one is time. Obama took over while the recession’s job losses were peaking and legislators were desperate to identify projects that could immediately put people to work. In Biden’s case, the economy is adding jobs, despite a weak report on Friday, and there’s already a $1.9 trillion stimulus law on the books. “I do think they’ve taken a lot of lessons from Obama,” said Carol Browner, chairwoman of the League of Conservation Voters and a former EPA administrator under Obama. “With Obama, the focus was very much on what we called ‘shovel ready’ projects. If I understand where the administration is, they won’t be limited to shovel ready; they recognize some of these investments take more time.” The challenges will still be significant.https://www.nbcnews.com/politics/white-house/biden-wants-trillions-infrastructure-big-hurdle-will-remain-spending-cash-n1265409
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For example, what if the partners in the year the audit is finalized are not the same partners as in the year that is being audited? There are several options available to partnerships that can mitigate the negative effects of a partnership-level assessment, which will be discussed later. As the regime is relatively new, partnership agreements may not be updated to incorporate some of the issues that arise in an audit under these circumstances. For example, if the partnership pays the tax, how will it be reported on the books? Will it reduce future distributions for the partners? How will allocations and capital accounts be affected? How will this affect the partners who were not partners in the year under audit? Partners should start thinking about addressing these issues in the partnership agreement now to avoid confusion later. The Importance Of The Partnership Representative The “Partnership Representative” (PR) under the BBA replaces the “tax matters partner” under TEFRA. The PR is not required to be a partner of the partnership but must have a substantial presence in the US with a US address, telephone number and Taxpayer ID Number. An entity can be a PR if an individual is also appointed. The PR is designated on the partnership tax return every year. If the entity fails to select a PR, the IRS will designate one. The PR plays a crucial role in the IRS audit process. Very close attention should be paid to who is designated. Under Code section 6223, the PR will have the sole authority to act on behalf of the partnership. The partners will be bound by the decisions and actions of the PR. Except for a partner who is the PR, no partner, or any other person, may participate in the examination process without permission of the IRS.https://www.fa-mag.com/news/irs-planning-50--increase-in-partnership-audits-59934.html