As of January 1, 2018, the rules that govern audits of partnerships have changed. In the past, the Tax Equity and Fiscal Responsibility Act (TEFRA) applied to these audits. The law required the Internal Revenue Service (IRS) to allocate the audit adjustments within partnerships amongst the partners.
The Internal Revenue Service (IRS) recently announced the Offshore Voluntary Disclosure Program (OVDP) is coming to a close. The program began in 2009 and modified versions have been used since its inception. It offers United States taxpayers the ability to voluntarily report foreign assets and come into compliance with applicable tax obligations.