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Partner Representative and the New Partnership Audit Regime

Volume 5 No 2    /    Read Article

By Simon H. Prisk

Commencing in January 2018, the I.R.S. began a new centralized audit regime with respect to partnerships. It replaces the concept of a "Tax Matters Partner" with a "Partnership Representative." This is more than a change in name. Unless the partnership is able to elect out of the new rules and actually does so, the I.R.S. will only deal with the Partnership Representative, and the individual partners have no right to separately appeal any tax assessment. Additionally, the I.R.S. may now collect tax at the partnership level as a result of a tax audit. Simon Prisk examines these and other changes - including the opt-out provisions - that will affect partnerships, partners in the current taxable year, and partners at the time that year is examined by the I.R.S.    See more →