A Roadmap for Hedge Fund Managers in Preparing For, Negotiating and Surviving IRS Partnership Audits

A recent program offered a roadmap for hedge fund managers in preparing for, handling and surviving IRS partnership audits.  The program specifically focused on trends, statistics and mechanics of partnership audits; partnership audit procedures and IRS staffing; five of the most important issues in current partnership audits; and best practices in preparing for an audit.  Many domestic hedge funds and management companies are structured as partnerships or other pass-through entities.  Accordingly, the discussion of IRS partnership audit issues has direct relevance to U.S. hedge fund managers, hedge funds and hedge fund investors.  This article summarizes the most noteworthy insights from the program.  See also “Hedge Fund Tax Experts Discuss Allocations of Gains and Losses, Contributions to and Distributions of Property from a Fund, Expense Pass-Throughs and K-1 Preparation at FRA/HFBOA Seminar (Part One of Four),” Hedge Fund Law Report, Vol. 7, No. 2 (Jan. 16, 2014).

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