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The authors note that the changes, which include the treatment of small partnerships, control over the audit process, and shifting of the tax bill from partners to the partnership, will render existing agreements obsolete and leave partners’ interests unprotected. They go on to explain:
"The changes, part of the Bipartisan Budget Act (BBA) of 2015, were designed to make it easier for the IRS to audit partnerships and to collect the additional taxes it assesses. The new audit procedures will apply to general partnerships, limited partnerships, limited liability partnerships, and multi-member limited liability companies that have elected to be taxed as partnerships."
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