New Regulations Issued: The Internal Revenue Service (“IRS”) has issued Final Regulations under the Bipartisan Budget Act relating to changes in the audit of entities taxed as partnerships (those which file IRS Form 1065 – which includes most Limited Liability Companies and Limited Partnerships) and how adjustments are allocated for such entities. A centralized partnership audit regime was established with a Partnership Representative required for each such entity. These changes are significant.

Act Now: It is important to amend any Operating Agreement or Limited Partnership Agreement you have to comply with these developments. Almost all such agreements need to be rewritten.

What You Should Do: Contact us. We are reviewing client files to determine which agreements should be amended and it is likely your documents need to be amended.