In a new article from The Practical Tax Lawyer, “Partnership Audit Regime Shakeup,” authors Nicola Lemay, Earl W. Mellott, and Abigail Wolf examine the Bipartisan Budget Act of 2015 and argue that careful consideration should be given now to how existing and new partnership agreements should be amended or drafted.
“The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The regime is expected to substantially increase the number of partnership audits and to generate billions of dollars in additional tax revenue. The new audit procedures will become applicable for partnership tax years beginning on or after January 1, 2018 (though it is possible for partnerships to opt into portions of the new procedures earlier).”
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