How to Not Get Crushed by Income Tax Collection from a Partnership - Centralized Partnership IRS Audit Rules: Biggest Change in History of Par

Description

Learn about Centralized Partnership IRS Audit Rules, one of the biggest changes in history of partnership taxation.  Partnerships will be taxed like C Corps if we don’t defend.

**Please Note:  If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to leighanne.conroy@acpen.com.

Highlights

• Not to get crushed by IRS collection of income tax from a partnership
• How the tax preparer can decimate a partnership’s future (or save it)
• To avoid ugly partnership level income tax at highest rate (and perhaps no basis step up for partners)
• To protect clients by electing out of new regime - who, how, when and why
• Congress’ Technical Corrections one month ago greatly expanded CPAR
• To identify whether S corporations may look better than partnerships now
• To lead your client to prepare in earnest today   

Objectives

• What is an “imputed underpayment” liability of a partnership? 
• What is a “push out” election and how does a partnership get decimated without it?
• May a partner do the right thing and “amend out” or “pull in”? 
• How must partnership/LLC operating, buy-sell, contribution, dissolution and loan agreements be revised to avoid problems?
• Who is a “partnership representative (PR)”? If we don’t choose one, IRS will for us (not even close to good)

Designed For

All CPAs