The new centralized partnership audit rules of the Bipartisan Budget Act of 2015 (BBA) replaced the Tax Equity and Fiscal Responsibility Act (TEFRA) audit procedures and the electing large partnership rules.

The new regime completely overhauls the IRS approach to partnership audits.  By default, the new audit regime allows the IRS to audit partnerships at the entity level and assess and collect taxes, penalties and interest against the partnership unless the partnership elects out of the new regime.  By design, this new regime empowers the IRS and is likely to lead to a higher audit frequency.

If you are a member of a tax partnership and a Schedule K-1 recipient, you need to know how your tax partnership will handle IRS audits

We assist business clients and their counsel, accountants, and other advisors with the following services:

• IRS partnership audit representation – for business clients
• IRS partnership audit representation – for accounting firms and law firms
• Partnership Representative counsel
• Design decision-making mechanisms
• Adapt LLC Operating Agreements and Partnership Agreements to new regime
• Tax compliance counsel – IRS Form 1065 and related Schedules