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All partnerships in most LLCs must amend their partnership and operating agreements due to new partnership audit rules effective January 1, 2018. These rules alter IRS audit proceedings, increasing audit capacity. However, small partnerships can opt out of these provisions by amending their agreements, with the election made annually alongside tax returns. Eligibility to opt out is restricted to partnerships with specific member types, including individuals and C or S corporations. Partnerships with trusts or tiered structures involving multiple partnerships are ineligible to opt out. Therefore, it is crucial for partnerships to review their structures and agreements in light of these changes.