Jerald David August Presented The ALI Webcast "The New Partnership Audit Rules: How Will They Impact Privately-Owned Businesses And Family Partnerships?"

This webcast included an inside look at the new centralized partnership audit regime and the challenges the IRS is addressing in the final regulations. Attendees heard a key IRS drafter of the proposed regulations in a give-and-take discussion with experienced counsel as he explained how the regulations are intended to work and explored the problem areas still under review. The panelists also examined issues in drafting and revising partnership agreements in response to the new rules.

Topics included:

  • The New Audit Rules: Background and General Principles
  • The Surprising Powers of the Partnership Representative
  • Annual Election Out for Eligible Partnerships
  • Imputed Underpayments; Computation and Mitigation of Amount
  • Push-Out Election under Section 6226
  • Statute of Limitations and Administrative Adjustment Request
  • Impacts on Tax Litigation
  • Partnership Agreement Impacts, including Sale of Partnership Interest, Mergers, and Divisions
  • Impact on Non-Resident or Foreign Partners; Withholding Impacts