The Impact of New U.S. Partnership Audit Rules on Investment Partnerships in the U.S. and Abroad: Hidden Mines in the Road to Increased Tax Revenue
The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986 that govern partnership audit proceedings. The new provisions are designed to simplify the ability of the IRS to conduct audits of partnership tax returns and collect any resulting tax liabilities. This article summarizes these rule changes and their implications for investment funds that are treated as partnerships for U.S. federal income tax purposes.