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More businesses are organizing as partnerships while fewer are C corporations. Unlike C corporations, partnerships do not pay income taxes but pass on income and losses to their partners. Some partnerships create tiers of partnerships with hundreds of thousands of partners. Tiered large partnerships are challenging for IRS to audit because tracing income through the tiers to the ultimate partners is complex. GAO's objectives include: 1 determine what IRS knows about the number and characteristics of large partnerships, 2 assess IRS's ability to audit them, and 3 assess IRS's efforts to address the audit challenges.
Congress should consider requiring large partnerships to identify a partner to represent them during audits and to pay taxes on audit adjustments at the partnership level. IRS should take multiple actions, including: define large partnerships, track audit results using revised audit codes, and implement project planning principles for the audit procedure projects.
IRS agreed with all the recommendations, but noted that revision of the audit codes is dependent upon future funding. Status : Closed - Implemented. In October , H. In November , the President signed this legislation into law. Matter : Congress should consider altering the TEFRA audit procedures to require partnerships that have more than a certain number of direct and indirect partners to pay any tax owed as determined by audit adjustments at the partnership level.
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Comments : In October , H. This legislation was signed into law in November According to the legislation, the new audit procedures would require partnerships to designate a qualified representative for the partnership audit. However, the legislation did not require audited partnerships to identify a representative who is an individual nor do they require that audited partnerships keep the designation up to date. The legislation does give IRS the authority to develop regulations about how the partnership representative should be designated by the partnership and such regulations may address the items in GAO's report.
The legislation specifies that the new partnership audit procedures apply to partnership returns filed for tax years beginning after December 31, In August , IRS released the final regulations on the partnership audit regime section notice to partners of proceeding T. Matter : Congress should consider altering the TEFRA audit procedures to require partnerships to designate a qualified Tax Matters Partner TMP and, if that TMP is an entity, to also identify a representative who is an individual and for partnerships to keep the designation up to date. Status : Open. Priority recommendation.
With changes to the Tax Equity and Fiscal Responsibility Act of partnership audit procedures and enactment of the Bipartisan Budget Act of BBA sections and of Public Law , IRS officials said that the number of partners is no longer a critical factor when defining a large partnership. IRS is correct that the number of partners is no longer relevant to this statutory definition of large partnership. The recently eliminated Electing Large Partnerships audit procedures had defined large partnerships as those with or more direct partners in a taxable year. Even so, IRS's new definition of large partnerships is limited compared to large corporations.
IRS has defined eight asset categories for tracking large corporation audit results while it has one for large partnerships, which vary widely based on asset amounts and complex structures. In tax year , more than two-thirds of these large partnerships had at least or more pass-through entities as direct and indirect partners.
As of December , IRS had revised its activity codes to create a category for its large partnership definition as well as created a reporting and monitoring structure for its new definition to track the results from auditing large partnerships. IRS also created reports to regularly track audit results e. IRS officials said they plan to use the reports to analyze audit results to identify opportunities to better plan and use resources in auditing large partnerships but this outcome may not be possible with the statutory changes governing partnerships.
Thus, IRS does not yet know whether the audit results will be sufficient to analyze ways to better plan and use IRS audit resources as well as to analyze noncompliance risk for its new definition. Recommendation : The Commissioner of Internal Revenue should track the results of large partnerships audits: a define a large partnership based on asset size and number of partners; b revise the activity codes to align with the large partnership definition; and c separately account for field audits and campus audits.
Comments : IRS agreed with our recommendation. As of December , IRS created a reporting and monitoring structure for its new definition to track the results from auditing large partnerships. IRS officials said they had started to look at how to use the audit results and did not have a timeline for when IRS will decide how to use the results for audit planning.
Thus, IRS does not yet know whether the audit results will be sufficient to analyze ways to better plan and use IRS audit resources as well as analyze noncompliance risk for its new definition. A more detailed definition, in line with the various size categories for large corporations, would allow IRS to complete more detailed analysis of large partnership noncompliance. Recommendation : The Commissioner of Internal Revenue should analyze the audit results by these activity codes and types of audits to identify opportunities to better plan and use IRS resources in auditing large partnerships.
Status : Closed - Not Implemented. In following up with IRS on the documentation in March , IRS officials said the day rule has not been extended but rather they attempted to improve IRS staff's understanding of the day rule. In addition, IRS determined that extending the day rule would not accomplish or improve the examination process. Recommendation : The Commissioner of Internal Revenue should extend the day rule to give field audit teams more flexibility on when to withdraw an audit notice. Theses included 1 revisions to an IRS publication to include examples illustrating how a person designated as TMP should sign IRS documents on behalf of the partnership, 2 developing a TMP information document request form to help IRS identify and validate the proper TMP early in the process, 3 adding lines to form to request TMP contact information, and 4 developing a new initial contact letter to the verify contact information of the TMP from the partnership.