Key Choices For Investors Under New Partnership Audit Rules

Law360 (December 10, 2018, 3:18 PM EST) -- Beginning in the 2018 tax year, IRS partnership tax audit adjustments will be assessed at the partnership level, not the partner level, and the partnership will owe the tax, penalties and interest. This can result in an inequitable result in the typical Foreign Investment in Real Property Tax Act, or FIRPTA, blocker structure since the blocker corporation typically accumulates net operating loss, or NOL, carryforwards which could offset their share of an IRS audit adjustment. Fortunately, the IRS has issued favorable regulations to address this scenario. However, the rules are complex and must be implemented correctly to get the desired tax...

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