Daily Tax Report Quotes Charles Ruchelman: IRS Revving Up Efforts to Find Partners Who Owe Tax

The Internal Revenue Service is working to develop better ways to find the partners or other investors who owe tax—and represent the most risk—in immensely complex partnership structures.

The agency said it will be focusing big resources on finding what it called “terminal investors”—those responsible for tax—in a new compliance strategy known as a campaign.

. . .  

In the unnumbered document detailing all 13 issues the agency is targeting, IRS said the partnership campaign “focuses on developing new procedures and technology to work collaboratively with the revenue agent conducting the TEFRA partnership examination to identify, link and assess tax to the terminal investors that pose the most significant compliance risk.”

Charles M. Ruchelman, a partnership specialist at Caplin & Drysdale, Chartered, pointed out that the statute of limitations goes back three years, so it is too soon to breathe a sigh of relief under the Bipartisan Budget Act.

He said a big question is “whether this has any impact that will really be visible to taxpayers. It appears that we're not going to see or be aware of what's going on behind the scenes. As someone who represents partnerships, we'd like to be a part of the process,” he told Bloomberg BNA Feb. 1.

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Excerpt taken from the article “IRS Revving Up Efforts to Find Partners Who Owe Tax” by Alison Bennett for Daily Tax Report.