Tax Strategy
Tax strategy is about far more than reducing this year's tax bill.
These articles explore proactive planning, entity selection,
owner compensation, state tax considerations, and the decisions that help privately held businesses
operate more efficiently over the long term.
Audit Shock: When the Partnership Pays the Tax
Under the BBA audit rules, the IRS no longer chases down individual partners for tax on audit adjustments. Instead, the partnership itself can be on the hook - leaving today’s partners paying for yesterday’s mistakes. This article breaks down how the rules work, including the imputed underpayment, the timing mismatch between the reviewed year and the adjustment year, the push-out election that can shift the burden back to reviewed-year partners, and provides some practice pointers.