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Construction and Real Estate Conference 2017


COR1738 - New Partnership Audit Rules


Dec 8, 2017 10:25am ‐ Dec 8, 2017 11:40am

Standard: $49.00

Description

The Bipartisan Budget Act of 2015 (BBA) overhauled the IRS audit process for partnerships and LLCs. Beginning in 2018, the IRS assessment and collection of underpaid taxes, penalties and interest takes place at the partnership level. Although several options exist to mitigate the amount of partnership-level underpayments, a decision is not so easy when adverse interests are involved (and as we will show, this frequently could be the case). During this presentation, we will review the new partnership audit rules and what should be done now to prepare for them. Planning for contingencies involving these rules will help the partnership, the partners and the “partnership representative” avoid contentious situations.

Learning Objectives:

  1. Describe the BBA's new partnership audit regime, including a summary of existing regulations and guidance
  2. List options available under the new rules to mitigate the imputed underpayment at the partnership level
  3. Explain the impact that the new rules may have on partners and partnerships, including several examples to demonstrate “routine” situations that can become contentious among the partners
  4. Recognize the importance of partnership/LLC agreement amendments to manage potential conflicts under the new rules
  5. Summarize the role of the “partnership representative” during the audit process

Speaker(s):

  • Rochelle Hodes, JD, LL.M. (Taxation), Associate Tax Legislative Counsel, US Department of the Treasury
  • Eliot Kaplan, Partner, Perkins Coie LLP
  • Nathan Smith, CPA, Director, National Tax Office, CBIZ
Tags: Combined

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