Journal of Investment Compliance Publishes Akin Gump Article on Impact of U.S. New Partnership Audit Regime on Asian Fund Managers
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Journal of Investment Compliance has published the article “Considerations for Asian fund managers under the U.S. New partnership audit regime,” written by Akin Gump investment management partner Anne-Marie Godfrey, and tax practice co-head Stuart Leblang, partner Ron Grabov-Nardini and senior counsel Monte Jackel.
The article examines how the Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, changes the way the IRS will conduct audits of collective investment vehicles treated as partnerships for U.S. tax purposes. In particular, the authors write, “it creates a liability at the level of a partnership for any unpaid tax.”
The authors offer some suggestions to those managers affected by the new audit regime. They also discuss some of its key points, noting that it is applicable “to any entity treated as a partnership for U.S. tax purposes that is required to file U.S. income tax returns or actually files returns as a partnership for U.S. tax purposes.”
To read the full article, please click here.
