Your club can opt out of the Centralized Partnership Audit Regime (CPAR), if you meet all of the following requirements:
- Your club tax return must include less than 100 K-1's total for current and former partners.
Your club only includes members who are:
- C corporations
- Foreign entities that would be treated as a C corporation if they were domestic entities
- S corporations - (But the number of K-1's they issue is added to the number of K-1's count. Total of both must be less than 100)
- Estates of any deceased partners
- All members have a US Taxpayer Identification number
- Your club files its tax return by the regular partnership return due date or extended due date based on a properly filed extension
Your club does not have any members who are:
- Foreign entities that would not be treated as C corporations were they domestic entities.
- A disregarded entity described in Regulations section 301.7701-2(c)(2)(i). (example: IRA's)
- A nominee or other similar person that holds an interest on behalf of another person.
- An estate of an individual other than a deceased partner.