Partnerships with foreign partners are subject to several federal tax requirements that do not apply to other types of businesses. For example, as the Internal Revenue Service (IRS) explains, in addition to filing an annual partnership tax return, “[p]artnerships . . . with foreign partners . . . could be responsible for [a] FIRPTA withholding, NRA withholding, and partnership withholding under sections 1446(a) and 1446(f) of the Internal Revenue Code (IRC).”

The Internal Revenue Service (IRS) regularly audits partnerships’ tax returns. For partnerships that have underpaid their federal tax liability, these audits can lead to substantial liability. They can also lead to scrutiny of individual partners’ returns in many cases.