Beginning in 2018, Congress enacted entirely new partnership examination procedures that replace the long-standing TEFRA audit procedures. Get an overview of the new examination process.
Dramatic changes and new terms & definitions must be understood. Virtually all existing partnership agreements must be reviewed and revised.
Identify the new partnership examination process
Determine the alternatives to imposition of tax at the partnership level
Recognize partnership agreement issues that must be addressed with legal counsel
Recognize and avoid conflicts of interest when advising and representing the partnership and/or partners
Overview of the New Partnership Examination Regime
Who “acts” for the partnership
Opt-out provisions in the rules
Tax at the partnership level
Avoiding tax at the partnership level and limitations
Representing the partnership and/or partners in an examination
Essential partnership agreement provisions
Unanswered matters including state tax authority responses
CPAs and tax professionals.
A minimum of two-years of partnership taxation experience.