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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, February 13, 2020

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel and advisers guidance to IRS rules on the designation of partnership representatives for purposes of the centralized audit rules. The panel will discuss the regulations under Section 6223 and the impact on pass-through entities, IRS procedural and administrative processes for audits, the use of disregarded entities as representatives, notice requirements, and potential issues in maintaining compliance.

Faculty

Guinevere M. Moore
Shareholder
Moore Tax Law Group, LLC

Ms. Moore serves as an attorney and a professional partnership representative to her clients. She has over a decade of experience representing taxpayers in high stakes disputes with the IRS. She represents taxpayers before the IRS and in litigation before the United States Tax Court, United States District Courts, Courts of Appeals, and the United States Supreme Court. She particularly enjoys her client counseling role and advising clients on how to navigate a dispute with the IRS. Ms. Moore also serves as Executive Director at US Partnership Representative, Inc.

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Rachel L. Partain
Member
Caplin & Drysdale Chtd

Ms. Partain's practice focuses on representing high-net-worth individuals (HNWIs), corporations, and TEFRA and other partnerships in complex federal and state tax controversy and litigation matters.

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Description

Recent IRS rules create a ripple effect on partnership designations, operating agreements, and potential tax liability. Counsel and advisers must have detailed knowledge of the scope of a partnership representative's role to avoid adverse tax consequences.

The application of the Section 6223 requirement that partnerships designate a representative with sole authority to act on behalf of the entity in matters related to IRS examinations requires careful consideration of a variety of factors. As a result, many partnerships modified existing partnership agreements and implemented a variety of compliance mechanisms to avoid unintended tax consequences in case of an IRS audit.

The final regulations provide clarity on essential items of concern, including allowing a disregarded entity to serve as a representative of the partnership and the removal of the capacity-to-act requirement for designated representatives along with extensive guidance on removing or replacing a partnership representative. The regs provide a roadmap for tax professionals to advise partnership clients on ensuring that the partnership representative can appropriately respond to the partnership's potential tax issues.

Listen as our experienced panel provides a thorough and practical guide to the IRS regulations on partnership representatives under Section 6223, IRS procedural and administrative processes for audits, notice requirements, and other high-priority considerations for partnerships.

Outline

  1. Overview of the IRS partnership audit regime
  2. Selection and responsibility of partnership representatives under Section 6223
  3. IRS final Section 6223 regulations
  4. Designating a disregarded entity as a partnership representative
  5. Failure to designate an eligible party as a partnership representative
  6. Terminating/replacing partnership representative
  7. Best practices and planning considerations for counsel in light of the final regulations

Benefits

The panel will review these and other essential concepts:

  • What are the fundamental changes that the final regulations make in Section 6223?
  • How does the change in the "capacity-to-act" provision impact the selection of partnership representative?
  • Changes to the provision allowing the IRS to designate a representative if the partnership has not made an eligible selection
  • How to change a partnership representative after the IRS has contacted a partnership about a possible audit
  • What are the rules governing the use of disregarded entities as partnership entities?
  • Planning considerations for partnership agreements and transactions in light of the final regulations

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the changes that final regulations made to Section 6223
  • Discern how the change in the "capacity-to-act" provision impacts the selection of partnership representative
  • Identify how to change a partnership representative after the IRS has contacted a partnership about a possible audit
  • Understand the rules governing the use of disregarded entities as partnership entities

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization with supervisory authority over other preparers/accountants in preparing complex tax forms and schedules and preparing for partnership audits. Specific knowledge and understanding of partnership structures and operating agreements and IRS partnership audits. Familiarity with new partnership audit rules under the Bipartisan Budget Act of 2015.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).