Description
Analyze the new partnership audit rules that are effective this year and gain a clear understanding of what partnerships need to know moving forward.Effective January 1, 2018, new Revised Partnership Audit Rules (Audit Rules) took effect, radically changing how entities taxed as partnerships will be audited and the resulting tax assessed and collected. The new Audit Rules adopt new concepts, procedures and elections. The tax resulting from the audit will now be assessed and collected from the partnership itself unless the partnership makes certain elections, including opt out, push out or pull in. The new Audit Rules require appointment of a partnership representative with Czarlike powers in dealing with the IRS audit. Unless a timely election is made, the economic burden of the tax resulting from the audit will be shifted from the persons who were partners in the prior audited year to the persons who are partners in the year the audit adjustments are final.
Date: 2019-12-05 Start Time: End Time:
Learning Objectives
Overview
Applicability (Section 6221)
Consistency Requirement (Section 6222)
Partnership Representative (Section 6223)
Partnership Adjustments (Section 6225)
Administrative Adjustment Requests (Section 6227)
Notice of Proceedings (Section 6231)
Assessment and Collection (Section 6232)
Judicial Review of Partnership Adjustment (Section 6234)
Statute of Limitations (Section 6235)
Drafting Consideration
CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Charles D. Pulman-Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., Matthew L. Roberts – Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., Mary E. Wood – Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.