The document discusses the impact of the Bipartisan Budget Act of 2015 on U.S. federal income tax audits of partnerships, specifically focusing on the BBA Rules and their implications for partnerships like the Access Fund. It outlines the potential tax liabilities for current and former partners, the elective alternative procedure, and the uncertainties surrounding the application of these rules. Additionally, it highlights other tax risks associated with investing in the Access Fund, including adverse changes in tax laws and the potential for substantial taxation.
doj/DataSet10/EFTA01382990.pdf
{"document_type":"financial","document_subtype":"tax legislation summary","key_organizations":["Southern Financial LLC","Access Fund"],"reference_numbers":["DB-SDNY-0082568","SDNY_GM_00228752","EFTA01382990"]}