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Course Details

TEFRA Who? A New Era For Partnership Audits

Webinar: ID# 1022892
Recorded CD
Qty:
About This Course:
At the end of 2015, Congress enacted the Bipartisan Budget Act of 2015, which introduced a new set of rules governing the federal income tax audit procedure for entities treated as partnerships for federal income tax purposes.

These rules represent a significant change in the partnership audit context and will take effect in taxable years beginning after 2017. Any taxpayers or businesses that have engaged in a joint venture or invested in entities that are partnerships for federal income tax purposes will want to understand the implications of this new regime on existing and future joint ventures.

The webinar will explain these new partnership audit rules and will provide practical solutions for addressing the new rules in existing and future partnership agreements.

Agenda

In the Beginning, Congress Created TEFRA
  • How Did We Get Here?
  • TEFRA – the Failed Experiment
  • What Went Wrong?
What Lead to the Bipartisan Budget Act of 2015
  • Motivations of Congress
  • Problems With Tefra
  • How Do the New Rules Address and Fix the TEFEA Issues?
The Nitty-Gritty – an Overview of the New Rules
  • Tax Matters Partner vs. Partnership Representative
  • Effective Dates
  • What to Do Now?
  • Elections
Issues Facing the New Rules
  • Effects on General Partners
  • How to Protect a Partner's Interests
  • Necessary Revisions to Partnership and LLC Agreements
  • Revisions for Creditors
To Pay the Entity Tax or Not to Pay, Opting out Is the Question
  • Fiduciary Duties for Partnership Representative
  • Do You Need Indemnity Insurance?
  • New Issues in Bankruptcy
  • How to Compute Entity Level Tax When You Have Tax-Exempt Partners
  • Myriad of Issues:
  • Differing Ordinary Income and/or Capital Gains Tax Rates Between Partners
  • Partners With NOLs
  • How Do the Rules Affect Capital Accounts
  • Do I Want to Join the Partnership? Issues Related to New Partners
About The Presenter

Madeline Chiampou Tully
  • Partner with McDermott Will & Emery
  • Represents clients on federal income tax matters relating to taxable and tax-free mergers, acquisitions and divestitures, corporate restructurings and finance transactions; within these areas, her tax practice focuses on energy tax issues, including advising on renewable energy transactions such as solar and wind projects
  • Significant experience in the planning, formation, operation and acquisition/divestitures of partnerships and partnership interests
  • An active member of the firm's Pro Bono and Community Service Committee
  • J.D. degree, Emory University School of Law; B.A. degree, magna cum laude, College of the Holy Cross
Kevin Spencer
  • BULLET 1
  • Partner with McDermott Will & Emery and focuses his practice on tax controversy issues
  • Represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions
  • Broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters
  • Prolific writer and lecturer on a variety of tax topics, and is an active member of the firm's Pro Bono and Community Service Committee
  • Adjunct law faculty member at Georgetown University Law Center and is an editor of the firm's Tax Controversy 360 blog
  • J.D. degree, cum laude, University of Miami School of Law; B.S. degree, cum laude, Mary Washington College, LLM degree, with distinction, Georgetown University Law Center
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TEFRA Who? A New Era For Partnership Audits
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