TEFRA audit rules have been repealed and procedures for partnership audits have changed. Partnerships are now responsible for audit adjustments, the role of "tax matters partner" has been replaced, and liability is now imposed on the partnership or LLC in the year of the adjustment, rather than the tax year to which the adjustment relates.
We advise members of LLCs taxed as partnerships and partners in partnerships to meet with their advisors to discuss these changes and amend their agreements to comply with the new audit procedures and the elections that are available to them.
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here for more information about TEFRA and the required amendments to LLC operating agreements.
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