How Not to Get Crushed By Income Tax Collections from a Partnership (Completed)

Centralized Partnership IRS Audit Rules (CPAR): Every Partnership (and LLC) Must Make a Stand and Other Freight Train Stories

Effective in 2018 (coming like a freight train), TEFRA partnership IRS audit rules are axed and a whole new regime kicks in. Partnerships may now be liable for income tax at 37%. IRS exams of partnerships will increase and become much more deadly. 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 colossal proportion.

Who Should Attend
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.

Topics Covered

• What affirmative actions must the tax preparer take to avoid a parade of horribles?
• 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 out" election and how does a partnership get decimated without it?
• How must partnership (and buy sell) agreements be revised to avoid train wrecks?
• Who is a Tax Representative anyway? Do they have any skin in the game? How to choose (and report) one and limit their power
• How and why 2019 busy season forces the tax preparer / planner to be on their game like never before

Learning Objectives

• Recognize how to advise partnerships to posture to sidestep and mitigate the harsh new effect of IRS dramatically broadened audit powers
• Identify how to prevent a partnership (or LLC) from becoming a strange new beast taxed at least in part as a C corporation

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (3 hours)

Program Prerequisites
None

Advance Preparation
None