Centralized Partnership IRS Audit Rules

Fight Back, Else Partnerships Become Strange New Beasts Taxed Like C Corps

Every Partnership (and LLC) Must Make a Stand

Written and Instructed by Bradley Burnett, J.D., LL.M. (Taxation)

(4 hour course)

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 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.

• 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 take to avoid a parade of horribles?
• Other partnership tax updates worthy of mention

IRS has been given too much power with these new rules
Learn to posture against and avoid train wrecks of biblical proportion