Massive Change in Partnership Taxation: Centralized Partnership Audit Rules (Currently Unavailable)
Author: Bradley Burnett
| CPE Credit: |
3 hours for CPAs
3 hours Federal Tax Law Updates for EAs and OTRPs
3 hours Federal Tax Updates for CTEC
3 hours Tax Planning for CFP |
Partnerships Taxed Like C Corps If We Don’t Defend - IRS Audits Rules Potentially Expensive
The IRS has made sweeping changes in his Centralized Partnership Audit Rules (CPAR) and those changes could bring nasty surprises for partnerships that aren't prepared. There are critical changes that might need to be made in your partnership clients' documents today in order to avoid potential disaster down the road on audit.
How many questions can you confidently answer?
What is an “imputed underpayment” liability of a partnership?
What is a “push out” election and how does a partnership get decimated without it?
May a partner do the right thing and “amend out” or “pull in”?
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/LLC operating, buy-sell, contribution, dissolution and loan agreements be revised to avoid problems?
Who is a “partnership representative (PR)”? If we don’t choose one, IRS will for us (not even close to good)
What IRS guidance has been issued and how does it change the game?
What affirmative actions must the tax preparer take to avoid a parade of tax horribles?
Don't let these changes sneak by you - join Bradley Burnett, J.D., LL.M., for this 3 credit on-demand course that will get you up to speed and have you dialing your partnership clients to make sure they are protected. The last thing you want is to see one of your partnership clients receiving a tax bill from the IRS at the partnership level.
Publication Date: July 2018
Designed For
All CPAs, EAs, tax preparers and staff who work with partnership taxation issues.
Topics Covered
- Avoid getting crushed by IRS collection of income tax from a partnership
- How can the tax preparer can decimate a partnership's future (or not)
- Avoid ugly partnership level income tax at highest rate (and no basis step up for partners)
- Steps a tax preparer can use to safely extricate a client from CPAR devastation
- Protect clients by electing out of new regime - who, how, when and why
- Congress' Technical Corrections in 2018 ago greatly expanded CPAR
- Identify whether S corporations may look better than partnerships now
- Lead your client to prepare in earnest today
Learning Objectives
- Explain IRS centralized partnership audit rules
- Discuss necessary steps with Clients to avoid potential problems on audit
- Recognize how the Partnership Documents and how they should be changed
- Describe correct statements, rules, and requirements with regard to CPAR
- Identify advantages and differences to a partnership of the "amend out" or "pull in"
- Describe the "push out" election
- Identify recommendations for how to best prepare for CPAR
- Describe how the new CPAR rules are effective for and what they replace
- Identify which form to use for an early election into CPAR
- Differentiate exit ramps with respect to the new CPAR rules
- Describe characteristics of a partnership and the regulations in various situations
- Recognize what occurs is a partner elects the amend out procedure
- Identify characteristics of intervening year
Level
Update
Instructional Method
Self-Study
NASBA Field of Study
Taxes (3 hours)
Program Prerequisites
Basic understanding of federal taxation of partnerships.
Advance Preparation
None
