Federal and State Partnership Audit Defense: BBA Audit Regime, Imputed Underpayment, Push-Out Election, Nexus
Recording of a 110-minute CPE webinar with Q&A
This webinar will detail how tax professionals and partnerships can appropriately respond to IRS examinations of partnerships. Our panel of pass-through entity experts will explain the BBA audit regime, address imputed underpayment calculations and modifications, and discuss when and how to make a push-out election.
Outline
- Introduction
- Brief overview of BBA regime
- Objective of training
- Understanding the imputed underpayment (IU)
- Concept of the imputed underpayment
- Base calculation formula
- IRS determination of adjustments
- Modifying the imputed underpayment
- Options for modification
- Available modification methods
- Process and timeline for modifications
- Push-out election process
- What is the push-out election
- Push-out election timeline
- Calculation of partner-level tax from push-out
- Example calculation
- Decision-making: pay IU vs. push out
- Nexus
- State audit process
- Preparing for state and local tax income tax audits
Benefits
The panel will review these and other critical issues:
- The BBA audit regime's impact on IRS examinations of partnerships
- How the imputed underpayment is calculated
- Tax-saving modifications to the imputed underpayment available under Regs. Sec. 301.6225-2(d)
- When a partnership should consider a push-out election
- Detailed examples including the mechanics of calculating and allocating push-out adjustments
Faculty
Will Hodges, CPA
Principal
Hancock Askew & Co.
Mr. Hodges is a principal and the partnership tax leader for Hancock Askew & Co LLP. He has extensive experience... | Read More
Mr. Hodges is a principal and the partnership tax leader for Hancock Askew & Co LLP. He has extensive experience gained in national partnership groups at both PwC and BDO where he advised clients on a range of complex partnership transactions, including mergers and acquisitions, initial public offerings, secondary offerings, Up-C transactions, leveraged partnership transactions, and debt workouts. Mr. Hodges expertise also extends to addressing issues related to capital account maintenance, special allocations, basis adjustments, and liability allocations. In addition to his time in public accounting, he led the tax function for a Family Office. Mr. Hodges experience working for a Family Office has given him unique insights into not only the technical aspects of transactions, but also the emotional aspects, making him an invaluable asset to his clients. He takes pride in advising clients through transactions – whether they are buying, selling, or restructuring.
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George W. Rendziperis, JD
Director
Baker Tilly US
Mr. Rendziperis is a director with Baker Tilly’s state and local tax (SALT) practice. He has more than 15... | Read More
Mr. Rendziperis is a director with Baker Tilly’s state and local tax (SALT) practice. He has more than 15 years of experience with assisting taxpayers in matters involving state income, franchise, gross receipts, sales and use, withholding, controlling interest transfer and real and personal property taxes, as well as unclaimed property and state tax credits and incentives. Mr. Rendziperis also provides experienced counsel in state tax controversies, audit defense and state tax litigation matters.
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