United States

The New Centralized IRS Partnership Audit Regime

Impacts taxpayers that conduct business through partnerships now and in the future.


Effective tax years beginning January 1, 2018, a new centralized IRS partnership audit regime will transform partnership audits and the assessment and collection of tax, affecting all taxpayers that conduct business through partnerships now and in the future.


The new regime:


Applies to all partnerships regardless of the number of partners


Imposes an entity level tax at a potential 39.6% tax rate


Replaces the Tax Matters Partner (TMP) with a Partnership Representative who has exclusive broad-ranging authority over the partnership and its partners

Sectors potentially impacted by the new regime:

Alternative Investments

Alternative Investments

Private Markets

Private Markets

Private Equity

Private Equity

Defining Issues: Recent IRS Audit Rules May Affect How Partnerships Account for Tax Underpayments

Read KPMG's new issue of Defining Issues that reports on the changes that partnerships may need to make to their financial reporting beginning in 2018.

> Read the report here



Privately Speaking: The Impact of the New Partnership Audit Regime on Privately Held Companies

Read KPMG's recent issue of our bi-monthly Privately Speaking newsletter, where we highlight the new proposed regulations and its significance to privately held companies.

> Read the newsletter here



Webcast Replay: The New Centralized IRS Partnership Audit Regime: Moving Forward Now…

In this Webcast replay, senior-level professionals from KPMG's Washington National Tax group and Tax Dispute Resolution Network present a review of the new regime, including:

  • An overview of the new partnership audit rules
  • The recently proposed regulations, including highlights of the important points
  • What taxpayers should be doing now to be prepared

(Original airdate: August 22, 2017)

Launch the replay here  


KPMG's Tax Controversies Services

Learn how KPMG’s Tax Controversies Services may help you prepare for the new Partnership Audit Regime.

> Click here for more information



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Contact Us

Miri Forster

Miri Forster

Principal, Tax Controversy Services, KPMG LLP

E: mcforster@kpmg.com


Ossie Borosh

Principal, Passthroughs Group, KPMG LLP

E: oborosh@kpmg.com


Curtis Wilson

Director, Practice, Procedure, and Administration, KPMG LLP

E: curtiswilson@kpmg.com


Deborah Fields

Principal-in-Charge, Passthroughs Group, KPMG LLP

E: dafields@kpmg.com


Harve Lewis

Director, Practice, Procedure, and Administration, KPMG LLP

E: harvelewis@kpmg.com

About KPMG's Passthroughs Services Group

The people, technology and industry experience to support the needs of partnership and passthrough entities.