Review when an adjustments by the IRS must be taken into account by the partnership.
When the revised IRS partnership audit rules took effect they radically changed how entities taxed as partnerships will be audited and the resulting tax assessed and collected. If the IRS makes a partnership adjustment for the reviewed year in the amount of any partnership-related item, and the adjustment results in an imputed underpayment, the imputed underpayment amount is paid by the partnership in the adjustment year as if a tax according to the new regulations. This white paper reviews this type of underpayment and discusses alternatives to partnership payment of imputed underpayments.
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