Impact of the New IRS Centralized Partnership Audit Regime
PLEASE NOTE: THIS PRESENTATION HAS BEEN POSTPONED UNTIL JANUARY 2019. NEW DATE WILL BE FORTHCOMING.
The new IRS centralized partnership audit regime rules (“New Rules”) apply to audits of partnership tax years beginning on January 1, 2018 or later. Under the New Rules, additional tax resulting from audit adjustments will be assessed and collected at the partnership entity level and, with certain exceptions, the partnership entity will be responsible for payment of any taxes and penalties that are assessed or will receive any refund that may be allowed. As a result, the tax burden or refund benefit from a prior tax year may be shifted from former partners, who were partners in the year under review, to the partners at the time of the audit adjustment. This presentation will identify issues arising in a partnership audit under the New Rules, suggest revisions to a partnership entity’s governing documents to conform to the New Rules and discuss implications for investors and partners who may sell a partnership.
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