A new centralized audit regime will soon govern IRS audits of all partnerships, including joint ventures, and could significantly impact the partners. The Bipartisan Budget Act of 2015 set in motion the end of the TEFRA partnership audit system that has been in place for the past 35 years; proposed regulations for a new regime were issued on June 12, 2017; and the new regime will apply for partnership years beginning after December 31, 2017.
With the new regime bringing substantial changes to partnership audits, taxpayers should learn what’s new and then review their partnership agreements, well in advance of the first filings due under the new regime, for any necessary revisions.
Please join Mayer Brown lawyers Bill Schmalzl, Kristin Mikolaitis and May Chow as they discuss:
- How the new regime will fundamentally change how partnership audits will be conducted and the payment of any resulting liability
- Which partnerships are eligible to elect out of the regime and, if so, whether they should
- Who, for partnerships covered by the new system, might serve in the newly created position of partnership representative
- How the economic liability for audit adjustments may fall on either the partners in the year to which the adjustment applies or the partners in the year in which the audit is concluded
CLE credit is pending.
Instructions for accessing the program will be sent prior to the event.
For additional information, please contact Shilpa Patel at firstname.lastname@example.org or +1 312 701 8487.