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New Centralized Partnership Audit Rules (ACNCP18)

 
Date:Saturday, December 9, 2017
Time:10:00AM - 12:00PM
(Registration at 9:30 AM)
Facility:Webcast or Webinar, Online
CPE Credit:2.0 Technical Business
Instructor: Bradley Burnett
Vendor:ACPEN
Course Level:Update
Early Bird Price:$79.00 FICPA Members, $109.00 Non-Members

Description:

Effective in 2018 (coming like a freight train), the TEFRA partnership audit rules are axed and a whole new regime kicks in.  Under the new rules, partnerships (and LLCs) will become strange new beasts potentially taxed like C corps.  Do these new "tax procedure" rules spell the beginning of the end for partnerships as we know them?  Escape routes are available, but not for all.  Advance planning is a must to avoid train wrecks of biblical proportion.



Objectives:

  • To understand how to advise partnerships to posture to sidestep and mitigate the harsh new effect of IRS dramatically broadened audit powers

  • To learn how to prevent a partnership from becoming a strange new beast taxed at least in part as a C corporation



    Major Topics:

  • Out with the old (TEFRA and ELP), and in with the new

  • Who can elect out of the new regime?

  • But wait, if you can’t elect out, can you switch things up so you can?

  • What is an "imputed underpayment" collectible against the partnership anyway?

  • What is a "push up" election and how does a partnership get decimated without it?

  • 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 (and buy sell) agreements be revised to keep it all fair?

  • Who is a Tax Representative anyway? Do they have any skin in the game? How to choose one and limit their power

  • What affirmative actions must the tax preparer and planner take to avoid a parade of horribles?



    Who Should Attend:
    Anyone who works with partnerships from a planning or compliance perspective. Anyone who owns a partnership interest and cares to not be devastated by IRS' extraordinarily broad new powers.

    Prerequisite:
    None

    Advanced Preparation:
    None

    Session/Options

    If listed below, select the appropriate sessions or options to continue with your purchase.

    Registration Status: CLOSED - Online registration for this course is now closed. Please contact the Member Service Center at (800) 342-3197 if you wish to inquire about registering.