Recent Changes to Rules Governing Tax Audits of Partnerships
Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S. partnerships. The amended rules provide opportunities and challenges for both existing and new funds, and should be considered by both fund sponsors and investors. These new rules will generally apply to years beginning after December 31, 2017, although a partnership may elect to apply the new rules to years beginning after November 2, 2015. This article provides an overview of the new rules and how they may affect partnership operating agreements.