Jonathan Stein, a member of Pryor Cashman’s Tax Group, will be speaking on the upcoming webinar, “New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes Ahead,” which will be held on March 9, 2016, commencing at 1:00 p.m. This webinar is an encore presentation of a January 20, 2016 program and will feature live Q&A.

This CLE/CPE webinar will provide tax counsel with a critical first look at the drafting, commercial and compliance implications of the new IRS regulations and procedures for auditing partnerships. The panel will describe the new partnership audit processes in detail, outlining the changes that will facilitate IRS audits of partnerships. The speakers will offer guidance on partnership agreement drafting provisions and other changes to partnership operations in preparation for the new audit processes.

Bipartisan Budget Act of 2015

Among the most far-reaching aspects of the Bipartisan Budget Act of 2015 is a significant change to the way the IRS audits partnerships. The new rules will replace the current Tax Equity and Fiscal Responsibility Act (TEFRA) rules. The new legislation will allow the IRS to audit partnerships at the entity level and assess and collect taxes against the partnership, unless the partnership elects out. The new rules will impact the formation and operations of partnerships, as well as disposition of partnership interests and admission of new partners.

The new law is designed to facilitate IRS audits of partnerships, thus leading to more audit frequency, and completely overhauls the Service’s approach to partnership examinations. The new audit approach will have significant effects on the drafting of partnership agreements. Tax counsel will have to consider issues such as protection of minority partners and specifying which party will bear the cost of taxes imposed at the partnership level.

Topics to be discussed during the webinar include:

• New audit rules
• Drafting and modifications required for existing partnership agreements
• Alternate procedures for partnerships seeking to opt out of entity-level assessments
• Impact on transfers of partnership interests and admission of new partners
• Procedural protections for minority partners

For more information and to register, please click here.