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Audits Bipartisan Budget

BakerHostetler

New Proposed Regulations Turn Off the Centralized Partnership Audit Rules in Certain Cases and Provide Guidance on QSub Partners

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On Nov. 20, 2020, the IRS and Treasury Department released proposed regulations on the centralized partnership audit rules enacted as part of the Bipartisan Budget Act of 2015 (the BBA Rules). The proposed regulations allow...more

Miles & Stockbridge P.C.

How You May Be Affected by the Changes to Partnership Audit Rules

In 2015, Congress passed the Bipartisan Budget Act that created a new Centralized Partnership Audit regime that is effective for income tax returns filed of partnership taxable years beginning after December 31, 2017. These...more

WilmerHale

New Partnership Audit Rules in Effect; Partnerships and LLCs Should Consider Changes

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A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more

Carlton Fields

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

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A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

BakerHostetler

Preparing for the New Partnership Audit Rules

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The Bipartisan Budget Act of 2015 substantially changed audit-related rules impacting entities taxed as partnerships, including both state-law partnerships and many limited liability companies (LLCs). The most significant...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here: Are You Ready? - Construction and Procurement Law News, Q3 2017

The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more

Eversheds Sutherland (US) LLP

Opting-In: Treasury Regulations Provide Rules for Electing into the New Partnership Audit Regime Early

As reported in a prior Sutherland Legal Alert, the Bipartisan Budget Act of 2015 (the 2015 Budget Act) makes significant changes to the procedural rules governing federal income tax audits and judicial proceedings that apply...more

Dickinson Wright

New IRS Audit Rules: Is Your Healthcare LLC Ready?

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The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

Foster Garvey PC

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

Foster Garvey PC on

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

Carlton Fields

Partnerships Must Respond to New Audit Rules

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The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

Smith Anderson

New Partnership Tax Audit Rules

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The Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such...more

K&L Gates LLP

IRS Sets Short Fuse for Comments, Guidance on New Partnership Audit Rules

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As if it wasn’t going to be busy already, the Internal Revenue Service (“IRS”) has set Tax Day, April 15, 2016, as the due date for comments on significant new partnership audit rules. This new law, which was enacted as part...more

Dechert LLP

Partnership Audits of Private Equity Firms on the Rise

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There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

Bradley Arant Boult Cummings LLP

Predicting How the New Partnership Audit Rules Will Affect S Corporations and Their Shareholders

This column has three focal points: S corporations (of course!), the new partnership audit procedures and Jeanne Dixon. Yes, that Jeanne Dixon—the self-professed psychic who claimed to have predicted the assassination of...more

Bradley Arant Boult Cummings LLP

Changes to IRS Partnership and LLC Rules

You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The IRS will be ramping up its...more

Foley Hoag LLP

Partnership Audit Regime Shakeup

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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 new audit...more

Allen Matkins

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

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One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...more

Dechert LLP

Navigating the New Partnership Audit Rules: Sea Change or Same Course?

Dechert LLP on

The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

Cozen O'Connor

New Partnership Audit Rules Require Careful Review of Partnership and LLC Agreements

Cozen O'Connor on

If you are a partner of a partnership or a member of a limited liability company (LLC) taxed as a partnership, or are entering into a new partnership or LLC, you may have some important decisions to make in light of impending...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Major Changes to Tax Audit Procedures to Impact Most Partnerships"

Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more

Holland & Knight LLP

New Audit Rules Require Changes to Partnership and LLC Operating Agreements

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The Bipartisan Budget Act of 2015 (P.L. 114-74) includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships, including limited liability companies (LLCs) taxed as...more

Baker Donelson

New Act Significantly Alters Partnership Audit Procedures

Baker Donelson on

The recently enacted Bipartisan Budget Act of 2015 repeals the current Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and Electing Large Partnership (ELP) partnership audit regimes and replaces them with a new...more

Troutman Pepper

The Game Has Changed: Congress Enacts Changes to IRS Partnership Audit Rules That Could Force Partnerships to Pay Tax - Tax Update...

Troutman Pepper on

The Bipartisan Budget Act will allow the IRS to collect taxes associated with audit adjustments at the partnership level, rather than passing adjustments through to the individual partners, effectively imposing entity-level...more

Akerman LLP

Bipartisan Budget Act of 2015 Introduces New Partnership IRS Audit Rules

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Effective for partnership tax years beginning after 2017, the Bipartisan Budget Act of 2015 repealed the current partnership audit rules and replaced them with rules described in general terms below. Partnerships can also...more

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