Statute of Limitations Considerations Under the BBA
Tax attorney James Dawson co-authored an article published by Tax Notes explaining how the centralized partnership audit regime creates problematic anomalies in the statue of limitations provisions and how partnership agreements can be drafted or amended to avoid these issues. Mr. Dawson also discusses the concept of adjustments and assessments, the Notice of Proposed Partnership Adjustment (NOPPA) and the Final Partnership Adjustment (FPA). The article also explains how the statue of limitations is determined by the procedural steps triggered by the NOPPA and how the IRS can assess the imputed underpayment against the partnership or the partners in the adjustment year.
READ: Statute of Limitations Considerations Under the BBA (Subscription required)