New Partnership Tax Audit Rules

Summary

This practice note discusses the partnership audit rules enacted under the Bipartisan Budget Act of 2015 (114 P.L. 74) and effective January 1, 2018. It provides an overview of the new partnership audit regime and highlights certain topics that tax practitioners should consider in representing partnerships and multimember limited liability companies (LLCs) that are taxable as partnerships. It also provides suggestions on tax provisions for partnership agreements and for other documents to take the new rules into account.