Home      Login

Abstract: 

New partnership audit rules that will take effect for taxable years beginning in 2018 will have a dramatic—and potentially detrimental—effect on partnerships and their partners. The new rules will affect private foundations that own partnership interests. In particular, it is a common estate planning technique to use a family limited partnership (FLP) to provide centralized asset management and liability protection, and to create a mechanism by which one generation can transfer wealth to the next without giving up control. Family foundations, their managers, and advisors all should be aware of the new rules.

Keywords: IRC §4943;“Pass-Through” entity; Tax Treatment of Prior Underreported Income; Increased Transfer Restrictions

Affiliations:  1: Strasburger & Price, LLP.