White Paper

What Happens When the IRS and Issuer Agree to Disagree?


The IRS may assess a tax deficiency against certain partnerships starting in January 2018.

Beginning on or after January 1, 2018, the IRS may assess a tax deficiency against certain partnerships rather than flowing the taxable income adjustment at the partnership level through to the individual partners and then collecting the additional tax from each individual partner.  This change in the Code was deemed to be a revenue raiser due to the increased efficiency in assessing the tax against the partnership rather than the individual partners.  



Cynthia C. Mog

Squire Patton Boggs

Cynthia Mog focuses her practice on federal income tax matters. She has experience working on corporate, partnership and real estate transactions including acquisitions, reorganizations, restructurings and tax-free exchanges.

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