New Centralized Partnership Audit Rules
Saturday, December 9, 2017
Effective in 2018 (coming like a freight train), the TEFRA partnership audit rules are axed and a whole new regime kicks in. Under the new rules, partnerships (and LLCs) will become strange new beasts potentially taxed like C corps. Do these new "tax procedure" rules spell the beginning of the end for partnerships as we know them? Escape routes are available, but not for all. Advance planning is a must to avoid train wrecks of biblical proportion.
*To understand how to advise partnerships to posture to sidestep and mitigate the harsh new effect of IRS dramatically broadened audit powers
*To learn how to prevent a partnership from becoming a strange new beast taxed at least in part as a C corporation
*Out with the old (TEFRA and ELP), and in with the new
*Who can elect out of the new regime?
*But wait, if you can’t elect out, can you switch things up so you can?
*What is an "imputed underpayment" collectible against the partnership anyway?
*What is a "push up" election and how does a partnership get decimated without it?
*Is it true Congress has eliminated basis step up in a partner’s interest for income fleshed out in an IRS exam?
*How must partnership (and buy sell) agreements be revised to keep it all fair?
*Who is a Tax Representative anyway? Do they have any skin in the game? How to choose one and limit their power
*What affirmative actions must the tax preparer and planner take to avoid a parade of horribles?