A little over 20 years ago, the Internal Revenue Service was reorganized from a geographically distributed service organization into the beginning of a technology driven organization based on four categories of customers: large businesses including international organizations, small businesses, not for profits, and individuals. At the same time, conversion from paper processing to electronic processing commenced in earnest, with the expectation of utilizing data driven efficiencies to facilitate taxpayer services, collection and enforcement. The lack of sustained funding, combined with the frequent enactment of increasingly complex tax laws, stalled completion of visionary technological changes expected for improved customer service and appropriately targeted efforts to defeat noncompliance. During 2022, $80 billion of additional long-term funding was promised. Will funds alone ensure a modern-functioning agency for the 21st century? What’s next?
For tax years beginning on or after January 1, 2018, partnerships that do not elect out of the federal centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA) cannot amend Forms 1065 or Schedules K-1. Instead, these partnerships must file an Administrative Adjustment Request (AAR). The novel AAR process is exceedingly complex for partnerships, as well as for partners that receive statements showing their allocable share of AAR adjustments. A few states have addressed how partnerships and partners should account for adjustments on a federal AAR, though most have not, adding further complexity to partnership tax compliance. The presenters will explain the process for filing a federal AAR, including situations where the partnership allocates adjustments to their partners, and discuss relevant forms such as the Form 8082, Form 8985, and Form 8986. The presenters will also describe the steps partners need to take if they receive an statement with their allocable share of AAR adjustments. In addition, the presenters will describe how states have addressed state tax filing obligations for partnerships filing federal AARs and their partners.
This session will cover the latest developments in tax planning opportunities and risks for real estate owners, developers and managers focusing on partnership structures that are the principal choice of entity. We will include a refresher on basic and intermediate transaction planning considerations and advanced creative planning concepts. Included will be a discussion of tweaks in the new Infrastructure law, and the risk of tax law changes, including on the shelf proposals yet to be enacted.
Over the last two years, the mergers and acquisitions market has been soaring, and so has the level of focus and diligence buyers are putting towards the tax compliance of target companies. This course will help participants prepare for questions that come up during tax due diligence and allow them to ensure their clients are ready for these questions well in advance of a liquidity event.
Congress and the IRS have made changes and are proposing more changes to IRA distributions. Learn the most recent information so you can guide your clients in this important area
This session will cover the latest guidance including proposed state and federal regulations and the latest topics in the AICPA Virtual Currency Task Force IRS comment letter. The panel will also discuss the practical challenges practitioners face when providing digital asset and virtual currency tax services other hot topics including the unique issues at the intersection of decentralized finance (DeFI), NFTs and the metaverse.
It is vitally important to stay on top of the latest updates and developments in trust and estate planning, especially in light of recent legislation and the evolving political landscape. During this presentation, you will be provided with practical advice and high-level tax guidance to advise your clients regarding the most tax-efficient planning techniques to help them achieve their objectives and goals. Topics covered will include limited family partnerships and family LLCs, trusts and estates, and charitable tax planning.
This presentation will provide coverage of the most significant court decisions, federal tax regulations and IRS rulings in 2022 relevant to all types of businesses and entities. These developments involve deductions, accounting methods, reasonable comp, and more. Highlights of the Inflation Reduction Act of 2022 relevant to businesses and federal tax form changes are also covered. Due diligence and planning considerations emphasized throughout.
Corporate stock options and partnership profit interest, while economically similar, have distinct differences that impact the tax implications of the service provider. In this session we will compare and contrast the two forms of equity-based compensation, including the differences in taxation, and consider alternatives to these awards, such as deferred compensation and appreciation rights. Also, we will consider the factors employers and service providers should consider when granting or receiving these awards, including whether it makes sense to convert employees into partners through profit interests.
This presentation covers highlights of the Inflation Reduction Act of 2022 that affect individuals, and the most important federal tax rulings of 2022 involving income, deductions, losses, virtual currency and other property, and procedural matters and their relevance to tax planning and compliance due diligence.