Significant Changes to IRS Partnership Audit Rules

On November 2, 2015, the Bipartisan Budget Act of 2015 was signed into law, the text of which can be found here. Among the provisions related to tax compliance, the Act imposes significant changes to the manner in which the IRS will determine audit adjustments related to partnerships.

Under the existing rules, in the case of smaller partnerships, the IRS generally follows the same audit procedures for individuals, whereas in the case of larger partnerships or partnerships with certain types are partners, adjustments are applied at the entity level pursuant the provisions of TEFRA (Tax Equity and Fiscal Responsibility Act of 1982).

Under the new rules, the IRS will by default determine adjustments at the partnership level and also render the partnership directly liable for the imputed underpayment and associated penalties, along with a number of additional procedural changes to the existing audit regime. A summary of the changes can be found here at pages 13 and 14.

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