Try our Advanced Search for more refined results

Expert Analysis

Key Choices For Investors Under New Partnership Audit Rules

By Brad Wagner (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 result....

Law360 is on it, so you are, too.

A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence. Over 200 articles are published daily across more than 60 topics, industries, practice areas and jurisdictions.


A Law360 subscription includes features such as

  • Daily newsletters
  • Expert analysis
  • Mobile app
  • Advanced search
  • Judge information
  • Real-time alerts
  • 450K+ searchable archived articles

And more!

Experience Law360 today with a free 7-day trial.

Start Free Trial

Already a subscriber? Click here to login

Related Sections

Law Firms

Government Agencies

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!