Mon, Dec 10, 2018
A A A
Welcome Guest
Free Trial RSS
Get FREE trial access to our award winning publications
Alternative Market Briefing

Other Voices: New partnership audit rules spell changes for private funds

Monday, April 30, 2018

By: Marc Finer, Murtha Cullina, LLP

New partnership audit rules became effective for tax years beginning on or after January 1, 2018. These rules, which are designed to make it easier for the IRS to audit partnerships and collect additional tax liabilities relating to partnership operations, apply to all partnerships and limited liability companies taxed as partnerships (hereinafter, "partnerships"). The New Rules do not require an amendment to the partnership agreement to be applicable. However, these rules will significantly impact partners/members (hereinafter, "partners"), and not updating the partnership agreement could eliminate the partners' ability to make certain elections and dictate the manner in which important decisions under the New Rules should be addressed. Moreover, unless certain options under the New Rules are addressed in the partnership agreement, potential investors may be reluctant to become partners.

This client alert provides a high-level summary of the new partnership audit rules and the amendments to partnership agreements that should be considered to address these rules:

Partnership Representative.Under the New Rules, the "partnership representative" is given the sole authority to act on behalf of, and bind, the partnership with respect to a partnership audit and other proceedings. The partnership representative is not legally required to notify the partners of an audit or keep them updated on the status of the audit. Importantly......................

To view our full article Click here

Today's Exclusives Today's Other Voices More Exclusives
Previous Opalesque Exclusives                                  
More Other Voices
Previous Other Voices                                               
Access Alternative Market Briefing

 



  • Top Forwarded
  • Top Tracked
  • Top Searched
  1. Northern Trust builds out alternative funds offering on wealth management platform[more]

    Laxman Pai, Opalesque Asia: Chicago-based asset manager Northern Trust has added private market capabilities to supplement the recently launched ArcLine Alternatives platform for the firm's wealth management clients. The administrator of assets worth $10.8tn said in a press note that the priv

  2. New Launches: Fidelity launches water and waste strategy, NewView Capital debuts with $1.35bn fund, Värde Partners raises $400m for Asia Credit Fund[more]

    Fidelity launches water and waste strategy From Investment Europe: Fidelity has unveiled a strategy focusing on sustainable investment opportunities within the water and waste management sectors. The Fidelity Sustainable Water and Waste Fund seeks to deliver strong risk adjusted returns a

  3. Activists: Neiman Marcus creditor steps up attack on MyTheresa transfer plan, Aphria calls shortseller claims 'false and defamatory', Marijuana stock Aphria plummeted as it fought a short seller who called out 'something very sinister'[more]

    Neiman Marcus creditor steps up attack on MyTheresa transfer plan From Business of Fashion: Neiman Marcus is once again feeling the heat. On Monday, one of its creditors - distressed debt investor Marble Ridge Capital - delivered an urgent letter to to the department store group's board

  4. Outlook: The economist who discovered the yield curve's predictive powers says he's getting worried, The 'big squeeze': Ray Dalio, founder of the world's largest hedge fund, breaks down how the next financial meltdown will look different from the last[more]

    The economist who discovered the yield curve's predictive powers says he's getting worried From CNBC: Arturo Estrella and his former Fed colleagues used to watch the relationship between the 10-year Treasury and the 3-month bill. A lot of people have been focused lately on the di

  5. People: Deutsche Bank appoints new country head in Switzerland, London's MENA Capital and Dubai's Al Mal agree collaboration deal, BlueBay appoints new CIO[more]

    Deutsche Bank appoints new country head in Switzerland From Investment Europe: Deutsche Bank has appointed Claudio de Sanctis as the new chief executive officer of Deutsche Bank (Switzerland) Ltd, effective 1 February 2019, after Peter (Pedro) Hinder decided to step down. The appoint