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.


*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?

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.



Advanced Preparation




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