The new IRS partnership audit rules, which are effective for partnership tax years beginning in 2018 and after, are here! For the first time, these rules give the IRS the ability to collect tax arising from adjustments to partnership-level and certain partner-level tax items directly from the partnership as opposed to collecting from each individual partner unless certain exceptions apply or necessary elections are made. This new regime can shift the economic burden of partnership-level audit adjustments among partners and adds new complexities which must be considered to avoid nasty surprises. It is imperative for investors in new or existing partnerships and purchasers and sellers of partnership interests or assets to know what to expect in the event of an IRS audit.
This webcast will provide a brief overview of the new partnership IRS audit rules that must be considered in M&A transactions involving partnerships. The webcast will then focus on the issues in the context of negotiating and documenting transactions and conducting tax due diligence with respect to partnerships.
Identify major provisions in the new partnership audit rules that may need to be considered in a proposed acquisition or disposition of a partnership interest or assets
- Describe the various ways that underpayments of tax may be paid under the new audit rules and the resulting economic burden potentially faced by the parties under different alternatives
- Identify issues to consider when engaged in due diligence in an acquisition or disposition of a partnership interest or assets
- Discuss potential issues and strategies, related to the partnership audit rules, in negotiating a purchase or sale of a partnership interest or assets
Recommended Field of Study:
Jose Carrasco, Senior Manager, Washington National Tax Office
Glenn Dance, Managing Director, Partnership Tax Services
Paul Beecy, Partner, Mergers and Acquisitions Tax Services
- Tom Geraghty, Partner, DLA Piper
Basic understanding of partnership tax principles
Group - Internet
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