Learn to identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions.

In 2015, Congress passed the Bipartisan Budget Act of 2015 (the BBA), which completely changed the way partnerships (and entities treated as partnerships) were audited and assessed tax by the IRS. The Department of Treasury and the IRS have issued guidance implementing the new audit procedures in the BBA, and these procedures generally are effective for taxable years beginning after December 31, 2018. This topic will help the persons responsible for the tax functions of partnerships understand the new partnership audit regime and the key differences from the old partnership audit regime, commonly known as TEFRA. The information will also help identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions involving partnerships.

Learning Objectives:-

• You will be able to define partnership representatives, designated individuals, and push-out elections.
• You will be able to describe major differences between TEFRA audit procedures and procedures under the new partnership audit rules.
• You will be able to explain the audit procedures now governing U.S. federal income tax returns for partnerships.
• You will be able to identify issues to consider when drafting partnership audit provisions in partnership agreements and key considerations in the M&A context.

Agenda:-

Background

• TEFRA Audit Procedures
• Reasons for Change
• Highlights of New Partnership Audit Rules

Comparing TEFRA and the New Partnership Audit Rules

• Scope
• Push-out Election
• Amendments and Pull-Ins

Tax Matters Partner vs. Partnership Representative

• Major Differences
• Designated Individuals
• Powers

Audit Procedure

• Under TEFRA
• Under the New Partnership Audit Rules
• Statute of Limitations Considerations

Practice Pointers

• Partnership Formation
• M&A Considerations

Who should Attend?

This live webinar is designed for:

• Accountants
• CPAs
• Controllers
• Attorneys
• Presidents
• Vice presidents
• Business owners
• Managers
• Enrolled agents
• CFOs
• Tax managers
• Finance directors
• Bookkeepers
• Tax preparers