Webinar

New Centralized Partnership Audit Rules

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.

Objectives

*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

Highlights

*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?

Additional Information

Designed For

Anyone who works with partnerships from a planning or compliance perspective. Anyone who owns a partnership interest and cares to not be devastated by IRS' extraordinarily broad new powers.

Vendor

ACPEN

Advanced Preparation

None

Prerequisite

None

Field of Study

Taxes

Course Number

171205603

Level of Knowledge

Update

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