Partnerships (which, for the purpose of this article, include limited liability companies treated as partnerships for tax purposes) have long been considered a flexible way of structuring investment arrangements and closely held businesses. Partnerships are not subject to entity-level corporate taxation and, unlike S corporations, they have flexibility to use special allocations and preferential distribution arrangements and to have various types of owners. However, partnership audit changes present increased exposure to partnerships and their partners, and future legislation may curtail much of the flexibility associated with partnerships. Now is a good time for partnerships and their partners to take steps to mitigate the potential consequences of the audit changes, and to anticipate potential legislative developments.