Megan Brackney presented at the American Law Institute course entitled “Representing Partnerships in Tax Audits, Controversies, and Litigation with the IRS,” on December 4, 2019.
The new partnership audit rules represent the most substantial change to audits in almost four decades. For partnerships, including LLCs taxed as partnerships, the opening of audits at this time and into the future will be governed by the new regime. In application, the new audit rules can significantly change audits and litigations, including who is responsible for tax payments and how deficiencies are attributed to partnerships, equating to a monumental tax procedure paradigm shift. Many practitioners possess a general understanding of these changes, but few possess an in-depth understanding of the impact these new rules will have. This program got down to the brass tacks of what the new audit rules look like in action - at formation, during the audit process, and on appeal, so that you can make more out of your pre-game planning!
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