IRS Partnership Audit Rules for Tax Counsel: Managing Partnership Operations and Governance
Partnership Agreement Drafting Considerations, Commercial Impacts, Transfers and Admissions of New Partners
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel with an up-to-date look at the drafting, commercial, and compliance implications of the partnership audit rules, including a discussion of IRS guidance on issues presented by the statute. The panel will describe the partnership audit processes in detail, outlining the changes that facilitate IRS audits of partnerships and strategies for tax counsel. The speakers will offer concrete suggestions on the partnership agreement and purchase agreement drafting provisions and other issues to consider with respect to the audit rules, including administrative relief granted in the wake of the CARES Act.
Outline
- A detailed discussion of the partnership 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
Benefits
The panel will review these and other critical issues concerning the IRS partnership audit processes:
- How the entity-level change facilitates IRS audits
- Role of the "tax representative" and "designated individual" with respect to audit
- Commercial and transitional issues
- Drafting and amending partnership agreements and purchase agreements
Faculty
Heath Martin
Counsel
Davies Ward Phillips & Vineberg
Mr. Martin's experience includes partnership drafting and defending individuals and businesses in federal and... | Read More
Mr. Martin's experience includes partnership drafting and defending individuals and businesses in federal and state tax audits. His practice also encompasses a broad range of domestic and cross-border transactions, including the formation and operation of private equity funds, hedge funds, REITS and other investment funds; public and private offerings of debt and equity; and mergers and acquisitions, including stock and asset purchases, tax-free reorganizations, restructurings and spinoffs. In addition, he has experience in the taxation of compensation arrangements and tax issues relating to tax-exempt organizations.
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Jonathan Stein
Director
Goulston & Storrs
Mr. Stein advises public and private companies, investment funds and real estate investors on corporate,... | Read More
Mr. Stein advises public and private companies, investment funds and real estate investors on corporate, partnership and international tax matters. He is experienced in representing buyers and sellers in taxable and tax-free M&A transactions; investment fund sponsors and institutional investors in fund formation and structuring of portfolio investments; and real estate investors and developers in optimizing complex joint venture strategies.
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