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OnDemand Course

Partnership Tax Audit and Collection Rules Including Final Regulations

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, new Revised Partnership Audit Rules (Audit Rules) took effect, radically changing how entities taxed as partnerships will be audited and the resulting tax assessed and collected. The new Audit Rules adopt new concepts, procedures and elections. The tax resulting from the audit will now be assessed and collected from the partnership itself unless the partnership makes certain elections, including opt out, push out or pull in. The new Audit Rules require appointment of a partnership representative with Czar-like powers in dealing with the IRS audit. Unless a timely election is made, the economic burden of the tax resulting from the audit will be shifted from the persons who were partners in the prior audited year to the persons who are partners in the year the audit adjustments are final.

99 minutes
Certificate of Completion
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Over 34 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

Applicability (Section 6221)

Consistency Requirement (Section 6222)

Partnership Representative (Section 6223)

Partnership Adjustments (Section 6225)

Administrative Adjustment Requests (Section 6227)

Notice of Proceedings (Section 6231)

Assessment and Collection (Section 6232)

Judicial Review of Partnership Adjustment (Section 6234)

Statute of Limitations (Section 6235)

Drafting Consideration

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Why Lorman?

Over 34 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

OnDemand Course

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, New Hampshire, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on August 28, 2019.

Call 1-866-352-9540 for further credit information.

  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • WA CLE 1.75
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.75 hours of A/V credit under the Law & Legal Procedure category.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 34 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]
Mary E. Wood

Mary E. Wood

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

  • Partner with the law firm Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
  • Practice concentrates on resolving federal and state tax controversies, and white collar crime such as securities, tax and bank fraud
  • Represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Courts, Federal District Courts and United States Court of Federal Claims; she also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies
  • Represents individuals and entities in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, noncompete violations, business torts, and other commercial disputes
  • Texas Rising Stars, as published in Texas Monthly and in Texas Super Lawyers - Rising Stars Edition and on the web at superlawyers.com, Tax-2013-2019; Best Lawyers Under 40, D Magazine, 2017
  • J.D. degree, with honors, University of Texas School of Law; B.B.A. degree in accounting, Texas A&M University
  • Can be contacted at 214-744-3700 or [email protected]
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Why Lorman?

Over 34 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: 406089
Published 2019
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