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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.

Learning Objectives

  • You will be able to recognize the specifics of the Partnership Representative
  • You will be able to identify the fundamentals of the Opt Out Agreement.
  • You will be able to differentiate between Partner Adjustments.
  • You will be able to identify Assessment and Collection proceedings

Runtime: 99 minutes
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Over 33 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 33 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 Webinar

This course was last revised on December 5, 2019.

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

  • CPE/NASBA - QAS Self Study 2.6 including Taxes 2.6
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study 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: 2.6 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.6 hours. Prerequisite: basic knowledge of general accounting. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement 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.
     
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Why Lorman?

Over 33 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; M.A. degree in taxation; B.A. degree in accounting, The University of Mississippi
  • Can be contacted at 214-744-3700 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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Product ID: 407226
Published 2019
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