IRS Partnership Audit Rules for Tax Counsel: Partnership Agreement Drafting Considerations, Transfers, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar 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 recent IRS enforcement actions. The panel will describe the partnership audit processes in detail, outlining the key items that facilitate IRS audits of partnerships. The speakers will offer concrete suggestions on partnership agreement drafting provisions and other changes to partnership operations in accordance with the audit processes.
Outline
- Detailed discussion of audit rules
- Drafting and modifications 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 discuss these and other critical issues concerning the IRS partnership audit processes:
- How the entity-level change facilitates IRS audits
- Elimination of concept of "tax matters partner" and requirement of "tax representative" with authority to represent the partnership in an audit
- Commercial and transactional issues arising from the partnership audit rules
- Drafting and amending partnership agreements
Faculty
Leah B. Segal
Attorney
Goulston & Storrs
Ms. Segal is a tax lawyer who counsels clients in a wide range of domestic and cross-border transactions,... | Read More
Ms. Segal is a tax lawyer who counsels clients in a wide range of domestic and cross-border transactions, including mergers and acquisitions, financings, offerings, and restructurings. Her practice includes advising clients on the tax aspects of various commercial real estate transactions, including joint ventures, acquisitions and dispositions, and tax credit deals. Her clients include privately held and publicly traded companies, family office investors, REITs and REMICs. Ms. Segal has experience representing charitable and other tax-exempt organizations in obtaining and maintaining tax-exempt status, as well as navigating ongoing governance and compliance issues. She also assists clients with charitable planning and has advised clients regarding tax implications of litigation.
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Alexandria (Andria) Williams
Attorney
Goulston & Storrs
Ms. Williams is an attorney in the firm’s tax group advising U.S. corporations, S corporations, and REITs. She... | Read More
Ms. Williams is an attorney in the firm’s tax group advising U.S. corporations, S corporations, and REITs. She advises clients on the tax implications related to a variety of mergers and acquisitions and securities transactions. Ms. Williams also researches and advises on tax structures, facilitates stock purchase agreements, handles SEC filings, and drafts prospectus disclosures for the issuances of equity securities. Additionally, her experience includes tax planning in connection with estate plans and trusts, as well as limited liability company agreements for single member and multi-member manager-managed limited liability companies holding real estate.
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