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Initiative 3.3 Expand enforcement for large partnerships
The IRS will increase enforcement activities to help ensure tax compliance of large partnerships
Where we are heading Key projects
The IRS has not had the resources in recent 1. Hire, onboard and train the staff needed
years to sufficiently address the significant to achieve appropriate compliance coverage
growth of partnerships. The number of rates. Strategically focus on hiring and training
partnerships increased by 32% in just a decade, to ensure appropriate resources to address the
from 3.2 million in tax year 2010 to 4.3 million variety of skill sets needed. Increase staff in the
in 2020. Partnerships with assets exceeding Independent Office of Appeals to resolve
$5 million grew even more, by 75%. Many of tax controversies arising from enhanced
5
these partnerships are complex, with many tiers compliance efforts. Increase staff in the Office
and sometimes thousands—or even hundreds of Chief Counsel to support both compliance
of thousands—of partner entities, each of which and appeals and to litigate cases when
can be a legally recognized entity such as an necessary. Hiring and training efforts
individual, corporation, foreign entity or another will focus on specialized enforcement
partnership. Because of their size and complex for large partnerships.
structure, partnerships require specialized 2. Develop approaches and new treatments
capabilities and often significant resources for large partnership enforcement by
to audit. In 2019, the audit rate for partnerships leveraging data and analytics. Explore
was 0.05%. 6
and pilot new compliance treatments for
large partnerships and refine existing tools
We will increase compliance coverage for large
partnerships to help ensure that their partners and processes for auditing them. Use improved
analytics to identify the most appropriate
are paying the taxes they owe. We will improve treatments to address potential noncompliance,
our tools and processes for auditing and
enforcement actions for large partnerships. given the issue-specific level of risk. Deploy
We will hire specialized compliance employees appropriate contacts to help these taxpayers
and train other employees to help ensure the resolve their compliance issues while also
applying sufficient approaches to promote
compliance of pass-through entities, with compliance.
a particular focus on enforcement for large
partnerships. We will use data and analytics
to improve our understanding of these complex Milestones
structures. We will pursue noncompliance through
a variety of mechanisms, including audit and FY 2023
non-audit treatments. 1 First wave of hires dedicated to large
partnerships hired and onboarded
to work toward increasing compliance
What success would look like coverage rates for large partnerships
Success for this initiative would include an FY 2025
increase in audit coverage and other types 2 Refined approaches and treatments
of enforcement of large partnership taxpayers piloted for large partnership enforcement
to improve voluntary compliance.
70 IRS IRA Strategic Operating Plan
Part II: Objectives and Initiatives
