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