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Live Webinar

100-minute live streaming program
  • March 16
  • 1:00 - 2:40 pm EST

New Partnership Audit Rules: What They Mean to Partnerships and Tax Professionals

March 16

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, the new Revised Partnership Audit Rules take effect, radically changing how entities taxed as partnerships will be audited and the resulting tax assessed and collected. The new Audit Rules drastically change the manner, procedures and consequences by which the Internal Revenue Service audits an entity taxed as a partnership and assesses and collects the resulting tax. The tax resulting from the audit will now be assessed and collected from the partnership itself unless the partnership elects to 'push-out' the tax to the persons who were partners during the audited year. The new Audit Rules alter the economic consequences of the audit and the relationship between partners. This topic will examine the new Audit Rules and provide suggestions how these new Audit Rules can be addressed in partnership agreements.

Learning Objectives

- You will be able to identify the components of a Partnership Adjustment.

- You will be able to determine when to make the Opt-Out Election and its effect.

- You will be able to analyze the Imputed Underpayment calculation and available Modifications.

- You will be able to review when to make the Push-Out Election and its effect.

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Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview
  • Background
  • Effective Date
  • Repeal of Old Sections and Addition of New Sections
Applicability (Section 6221)
  • General Rule Regarding Determinations and Applicability to All Partnerships
  • Option to Elect out for Certain Partnerships With 100 or Fewer Partners
Consistency Requirement (Section 6222)
  • Consistency Generally Required
  • Failure to Be Consistent
Partnership Representative (Section 6223)
  • Designation
  • Eligibility
  • PR Designation, Resignation, and Revocation
  • IRS Designation
  • Binding Effect of PR
Partnership Adjustments (Section 6225)
  • Imputed Underpayment
  • Non-Imputed Underpayment Adjustments
  • Alternative to Payment of Imputed Underpayment Amount by Partnership ("Push out Election") (Section 6226)
  • Tax Attribute Adjustments
  • International Tax Adjustments
Administrative Adjustment Requests (Section 6227)
  • General
  • Adjustment
  • Period of Limitations
  • Where NOAPP Issued
  • Form
  • Partner Modification
  • Push out Election
  • No Imputed Underpayment Amount
  • Penalties
  • Refunds
  • Disregarded Provisions
  • Use of AAR in Lieu of Amended K-1
  • Use of AAR by Partnership/Partner Subject to Push out
  • International Tax Adjustments
Notice of Proceedings (Section 6231)
  • General Notice Requirements
  • Timing
  • Address for Notices
Assessment and Collection (Section 6232)
  • Method for Assessing and Collecting
  • Timing
  • Mathematical or Clerical Adjustments
  • Mathematical or Clerical Errors for Upper-Tier Partnerships
  • Partnership Waivers
  • Interest and Penalties (Section 6233)
Judicial Review of Partnership Adjustment (Section 6234)
  • Lawsuit to Challenge FPA
  • District Court and Court of Federal Claims
  • Interest
  • Scope of Judicial Review
  • Appeals
  • Effect of Dismissal
Statute of Limitations (Section 6235)
  • Statute of Limitations - Three Time Periods
  • Agreements to Extend
  • Exceptions
  • Suspension of Statute of Limitations
  • Bankruptcy Proceeding
  • Appealing IRS Determination Under PAR
  • Information Returns
  • Entities Filing Partnership Return
  • Partnership Ceases to Exist
  • Partnership Payments Non-Deductible
  • Other Special Provisions (Section 6241)
Drafting Consideration
  • Partnership Agreement
  • Other Affected Agreements
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Live Webinar Registration

  • AIPB 2.0
     
  • This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AL CLE 1.7
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.7 hours credit.
     
  • AR CLE 1.75
     
  • This course has been approved for 1.75 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CO CLE 2.0
     
  • This program may qualify for 2.0 credit hours through the Colorado Supreme Court Board of Continuing Legal and Judicial Education through reciprocity. This course is accredited in other jurisdictions such as New Jersey. To receive CLE credit for this program, a home study affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • GA CLE 1.7
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.7 CLE hours.
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MS CLE 1.7
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.7 credit hours.
     
  • MT CLE 1.75
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.75 CLE credits.
     
  • NH MCLE 1.7
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 100 Minutes.
     
  • NJ CLE 2.0
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2.0 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 2.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 2.0 hours of CLE credit.
     
  • TN CLE 1.67
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.67 hours of credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of CLE credit.
     
  • WA CLE 1.75
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.75 hours of Law & Legal Procedure credit.
     
  • WI CLE 2.0
     
  • This program has been approved by the Board of Bar Examiners for 2.0 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 2.0
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 2.0 MCLE hours.
     
  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     
  • CPE 2.0 including Taxes 2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.0 hours. Prerequisite: basic knowledge of general accounting. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 2.0 hours.
     
  • Lorman Business Center, Inc. has registered with the Texas State Board of Public Accountancy as a CPE Sponsor. This registration does not constitute an endorsement by the Board as to the quality of our CPE Program. This program qualifies for 2.0 hours of continuing professional education.
     

Who should attend?

This live webinar is designed for accountants, CPAs, CEOs, presidents, vice presidents, CFOs, controllers, business owners and managers, bookkeepers, tax preparers, enrolled agents and attorneys.

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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Charles D. Pulman

Charles D. Pulman

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

  • Tax partner with the Dallas law firm of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
  • Practice focuses primarily on federal tax planning and compliance with extensive experience representing taxpayers under IRS audit and the resulting administrative and judicial proceedings
  • Extensive experience representing entities taxed as partnerships and their partners
  • Represents clients on tax matters throughout the United States
  • Board certified in Tax Law by the Texas Board of Legal Specialization; he is also a Certified Public Accountant
  • Writes and speaks extensively on tax related topics and has written and spoken on several occasions with regard to the new IRS audit regime affecting partnerships
  • Recognized by his peers as a Texas Super Lawyer and recognized as one of the Best Lawyers in Dallas by D magazine
  • LL.M. degree in taxation, New York University
  • Can be contacted at 214-749-2447 or [email protected]
Matthew L. Roberts

Matthew L. Roberts

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

  • Senior tax associate with the law firm Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
  • Represents individuals, estates, partnerships, and large corporations in all stages of a tax dispute, including IRS examinations, administrative appeals, and litigation in the U.S. Tax Court and Federal District Court
  • Practice also includes domestic and international Income Tax and Business Planning
  • From 2012-2015, he was an attorney-advisor for The Honorable Chief Judge Michael B. Thornton, United States Tax Court in Washington, D.C.
  • Since its enactment, he has written articles and has participated in speaking engagements on the new centralized partnership audit rules
  • LL.M. degree in taxation, New York University School of Law; J.D. degree, summa cum laude, University of Mississippi School of Law; Masters of Taxation and his Bachelors of Accounting, The University of Mississippi
  • Can be contacted at 214-744-3700 or [email protected]
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 402977
Published 2018
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