- NY Credits : 3.0
- TX Credits : 3.0
- IRS Enrolled Agent Credits : Federal Tax/Tax Related Matters - 3.0
- IRS Non-Credentialed Return Preparer Credits : Federal Tax - 3.0
The New IRS Partnership Audit Rules
The Bipartisan Budget Act of 2015 (BBA) revolutionized how the IRS approaches partnership audits. The old TEFRA audit regime has been jettisoned in favor of new set of centralized partnership audit rules, which imposes a partnership-level obligation for amounts due to audit adjustments and does away with the tax matters partner in favor of a partnership representative, among other significant changes. Over one hundred pages of proposed regulations have been issued to implement these changes. This course describes the salient portions of those proposed regulations and describes what practitioners should know about them to be ready for the implementation of these new rules.
This course is most beneficial to professionals new to partnership rules who may be at the staff or entry level in organization but also for a seasoned professional with limited exposure to this subject.
Upon successful completion of this course, the user should be able to:
recognize difference between TEFRA audits and centralized partnership audits, procedures used by IRS in centralized partnership audits, effect of imputed underpayment on outside basis and capital accounts, and how bankruptcy code affects centralized partnership audit rules;
identify partnership representative qualifications, bases for requesting modification to an imputed understatement, consequences of adjustment do not result in an imputed underpayment, consequences to a push out election on partners, and centralized partnership audit issues concerning RICs and REITs;
describe procedures for electing out of centralized partnership audit regime;
calculate imputed underpayment and safe harbor amounts related to push out statements; and
determine procedures necessary for requesting administrative adjustment and effect of a partnership termination on partnership adjustments.