SHARE

September 23, 2022

IRS Official Provides Update on Large Partnership Compliance Audits

You've Reached Your
Free Article Limit This Month
Register for free to get unlimited access to all Law.com OnPractice content.
Register Now

Almost 11 months ago, the Internal Revenue Service (IRS) released a memorandum regarding the implementation of the Large Partnership Compliance (LPC) Pilot Program, including the identification, selecting and delivery of large partnership tax returns, exam procedures and feedback. The goal of the LPC program is to identify the largest partnership cases and develop improved methods for identifying and assessing the compliance risks presented by these taxpayers. Large partnerships include those with more than $10 million in assets, and such partnerships are subject to data analytics and classification processes. Audits of these large partnerships are conducted by the Large Business & International (LB&I) division.

The LPC program was discussed at the recent Tax Executives Institute conference in New York. IRS officials noted that 50 large partnerships have been selected for the first round of audits, focusing on the 2019 tax year. The IRS currently is undecided as to whether LB&I plans to audit subsequent year returns for the selected partnerships, but likely will not subject such partnerships to a continuous audit process that is used for many large corporate taxpayers.

An interesting discussion took place at the conference related to whether IRS revenue agents will share with the selected partnerships the risk level assigned to their partnership return and which issues will be examined. (Risk assessment and identification of issues are generally included in audit plans for corporate taxpayers, although the level of risk may not necessarily be disclosed.) Currently, some agents are providing such information to selected partnerships but there is no consensus or standard practice at the audit level.

Practice Point: The IRS has made it well known that large partnerships are on their radar and there is a need to focus on these audits to ensure taxpayer compliance. In our experience, revenue agents tend to be more transparent in audits of large taxpayers when it comes to the issues under examination, but it would be a welcome development if the IRS announced at the outset of the audit more standard procedures for informing taxpayers of the risk levels assigned. As the LPC program continues, we are hopeful that the IRS will decide to share more data with the public. We expect an increase in audit activity as a result of additional funding received by the IRS, and it appears that the IRS will focus those efforts on large partnerships.

Tags

ALM expressly disclaims any express or implied warranty regarding the OnPractice Content, including any implied warranty that the OnPractice Content is accurate, has been corrected or is otherwise free from errors.

More From McDermott Will & Emery

Merck Fosters Healthcare Of The Future

By McDermott Will & Emery attorneys McDermott Will & Emery December 02 , 2022

Artificial intelligence and machine learning have led a digital transformation in healthcare, expanding providers’ resources and improving the lives of people around the world.

A Tsunami of Lawsuits Is Expected to Slam Institutions in the Wake of New York Adult Survivors Act

By Greer Griffith McDermott Will & Emery December 01 , 2022

A new revival window opened on Thanksgiving Day for filing sexual assault and abuse lawsuits that would otherwise be time-barred by the New York statute of limitations.

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

By Andrew R. Roberson McDermott Will & Emery December 01 , 2022

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v. Commissioner).

More From Tax

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

By Andrew R. Roberson McDermott Will & Emery December 01 , 2022

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v. Commissioner).

Treasury Announces Initial Guidance on the Inflation Reduction Act's Labor Requirements for Renewable Energy Tax Credits and Incentives

By John Eliason Greenberg Traurig November 30 , 2022

The U.S. Department of the Treasury announced initial wage and apprenticeship guidance under the Inflation Reduction Act of 2022 (IRA) that applies to taxpayers in order to increase available credit amounts for federal tax incentives, including the Investment Tax Credit (ITC) and Production Tax Credit (PTC).

IRS Issues New Procedures for Large Corporate Audit Disclosures

By Andrew R. Roberson McDermott Will & Emery November 30 , 2022

For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal Revenue Service (IRS) of adjustments (both positive and negative) to their tax returns and thereby obtain protection from various penalties and obviate the need to file a formal amended tax return. In 2020, the IRS questioned the continuing utility of this disclosure process and invited comments on said process.

Featured Stories
Closeclose
Search
Menu

Working...