A discussion of the changes in how partners deal with each other and the IRS under the new partnership audit rules partnership representative rules. And how these rules will affect provisions of partnership agreements, relationships among current and former partners.
An understanding of what we know, what we know we don't know, and don't know we don't know about the new partnership audit rules.
An understanding of changes in the relationship among partners, former partners, the partnership representative, and the person making tax decisions that result from the new rules.
A discussion of how partnership agreements and operating agreements need to change to deal with the new rules.