Selected Partnership Tax Issues
1 hour 40 minutes
Learn to identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions.
In 2015, Congress passed the Bipartisan Budget Act of 2015 (the BBA), which completely changed the way partnerships (and entities treated as partnerships) were audited and assessed tax by the IRS. The Department of Treasury and the IRS have issued guidance implementing the new audit procedures in the BBA, and these procedures generally are effective for taxable years beginning after December 31, 2018. This topic will help the persons responsible for the tax functions of partnerships understand the new partnership audit regime and the key differences from the old partnership audit regime, commonly known as TEFRA. The information will also help identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions involving partnerships.
• You will be able to define partnership representative, designated individual and push-out election.
• You will be able to describe major differences between TEFRA audit procedures and procedures under the new partnership audit rules.
• You will be able to explain the audit procedures now governing U.S. federal income tax returns for partnerships.
• You will be able to identify issues to consider when drafting partnership audit provisions in partnership agreements and key considerations in the M&A context.