New Partnership Audit Rules Go Live

The Bipartisan Budget Act of 2015 (“BBA??) fundamentally changed the rules by which partnerships, and entities taxed as partnerships (such as limited liability companies), interact with the Internal Revenue Service (“IRS??) in an audit or litigation. The new rules apply to partnership tax years beginning on or after January 1, 2018. We outlined these significant changes to the partnership audit rules in a prior Alert. The BBA repealed the 30 year-old TEFRA partnership audit regime, upending or creating uncertainty with respect to previously-settled partnership tax rules and procedures. Many of the implemented regulations remain in proposed form and offer no guidance on certain critical issues. Given the myriad uncertainties and burdens of the new regime, U.S. and foreign partnerships (and their advisors) should take steps now to mitigate their risk.  READ MORE

A New Era of Partnership Representation Before the IRS

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