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Alternative Market Briefing

Partnership structure for hedge funds trips up IRS auditors

Tuesday, August 05, 2014

Bailey McCann, Opalesque New York:

A new report from the US General Accounting Office (GAO) shows that the partnership structure of hedge funds and private equity firms is tripping up IRS auditors. The report notes that partnerships typically have fewer IRS audits, and when they are audited the net change of reported income is so small, the GAO has asked if IRS auditors can effectively audit the structure.

"Internal Revenue Service (IRS) data show, from tax years 2002 to 2011, the number of large partnerships more than tripled. According to IRS officials, many large partnerships are hedge funds or other investment funds where the investors are legally considered partners. Many others are large because they are tiered and include investment funds as indirect partners somewhere in a tiered structure. According to IRS data, there were more than 10,000 large partnerships in 2011. A majority had more than 1,000 direct and indirect partners although hundreds had more than 100,000. A majority also had six or more tiers," the report explains noting that the regulator only audits 0.8% of partnerships compared to over 27% of corporations.

"These minimal audit results may be due to challenges hindering IRS's ability to effectively audit large partnerships. Challenges included administrative tasks required by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the complexity of large partnership structures due to tiering and the large number of partners. For......................

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