Description
The partnership audit rules allow the IRS to audit partnerships at the entity level and assess and collect taxes against the partnership unless it elects out of the regime. This impacts the formation and operations of partnerships, as well as the disposition of partnership interests and the admission of new partners.
The rules are designed to facilitate IRS audits of partnerships, thus leading to more audit frequency, and completely overhauled the Service's approach to partnership examinations. The audit rules have a significant effect on the drafting of partnership agreements and purchase agreements. Tax counsel will have to consider issues such as protection of minority partners, specifying which party will bear the cost of taxes imposed at the partnership level and indemnities for pre-closing taxes.
The rules address several procedural and substantive tax issues. Tax counsel should evaluate existing partnership agreements to prepare clients for the commercial, operational, and compliance impact of the audit rules, as well as incorporating the law's provisions for all new partnership agreements, purchase agreements, and agreements in connection with the winding up of a partnership.
Listen as our expert panel provides a critical analysis of the impact of the partnership audit rules. The panel will offer insights on how to address the changes brought about by the audit processes and detail the commercial and operation concerns arising from the audit rules.
Presented By
Mr. Martin's experience includes partnership drafting and defending individuals and businesses in federal and state tax audits. His practice also encompasses a broad range of domestic and cross-border transactions, including the formation and operation of private equity funds, hedge funds, REITS and other investment funds; public and private offerings of debt and equity; and mergers and acquisitions, including stock and asset purchases, tax-free reorganizations, restructurings and spinoffs. In addition, he has experience in the taxation of compensation arrangements and tax issues relating to tax-exempt organizations.
Mr. Stein advises public and private companies, investment funds and real estate investors on corporate, partnership and international tax matters. He is experienced in representing buyers and sellers in taxable and tax-free M&A transactions; investment fund sponsors and institutional investors in fund formation and structuring of portfolio investments; and real estate investors and developers in optimizing complex joint venture strategies.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Thursday, July 30, 2020
- schedule
1:00 p.m. ET./10:00 a.m. PT
- A detailed discussion of the partnership audit rules
- Drafting and modifications required for existing partnership agreements
- Alternate procedures for partnerships seeking to opt-out of entity-level assessments
- Impact on transfers of partnership interests and admission of new partners
- Procedural protections for minority partners
The panel will review these and other critical issues concerning the IRS partnership audit processes:
- How the entity-level change facilitates IRS audits
- Role of the "tax representative" and "designated individual" with respect to audit
- Commercial and transitional issues
- Drafting and amending partnership agreements and purchase agreements
Learning Objectives
After completing this course, you will be able to:
- Identify the partnership audit rules
- Discern modifications required for existing partnership agreements
- Determine alternatives for partnership op-outs of entity-level assessments
- Ascertain procedural protections available to minority partners
- 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.
BARBRI 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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