How to Avoid Getting Crushed by Income Tax Collection: Centralized Partnership Audit Rules (Completed)

Effective for Forms 1065 filed in 2018 and later (the freight train has arrived), 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 that IRS may audit and collect income tax from. 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.

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

• 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 an "amend out" or "pull in" and how can it help?
• 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 keep it all fair?
• Who is a Tax Representative anyway? How to choose one and limit their power
• What affirmative actions must the tax preparer take to avoid a parade of horribles?

Learning Objectives

• Recognize how to advise partnerships to posture to sidestep and mitigate the harsh new effect of IRS dramatically broadened audit powers
• Identify awareness and appreciation of other current planning opportunities and curses affecting partnerships

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (3 hours)

Program Prerequisites
None

Advance Preparation
None