With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015, the IRS can now audit certain “large” partnerships, instead of each of their partners, and assess income tax, interest and penalties against the partnership itself. IRS partnership audits have begun and a group of “super auditors” are completing their training. We also learned from IRS officials that a surprising number of not-so-large partnerships didn’t exercise their annual right to opt-out of the comprehensive partnership audit regime (CPAR), and are therefore subject to the new audit rules – whether they like it or not. Read more >>