New IRS Partnership Audit Rules for Private Equity and Hedge Funds
Partnership Level Tax, Push-Out Elections, Partnership Representative Provisions and More
Recording of a 90-minute premium CLE webinar with Q&A
This CLE course will examine the new IRS partnership audit rules and their impact on private equity and investment funds. The panel will discuss the changes that should be made now in partnership and LLC agreements in contemplation of the new rules, the elections available to smaller partnerships to avoid the new partnership level audits, and "push-out" elections which will allow for adjustments for changes in ownership.
- The Bipartisan Budget Act of 2015 and phase-in of the new partnership audit rules
- Exceptions and opt-out rules
- Implications of partnership level tax vs. individual partner level tax
- Issues for private equity and other investment funds
- Partnership representative—new final regulations issued under Section 6223
- Suggested amendments to existing partnership or LLC agreements
The panel will review these and other key issues:
- What options are available to smaller partnerships and LLCs that wish to opt out of the partnership-level taxation requirement?
- How should private equity funds address tax inequities resulting from changes in ownership from one year to the next?
- What amendments should be made to include a "partnership representative" in existing partnership or LLC documents?
Christopher T. Bird
Mr. Bird is a business tax lawyer with eight years of experience at large international law firms. His practice... | Read More
Mr. Bird is a business tax lawyer with eight years of experience at large international law firms. His practice principally focuses on U.S. and cross-border tax matters relating to taxable and tax-free mergers and acquisitions, debt and equity financings, and the formation of pooled investment vehicles.Close
Morgan L. Klinzing
Troutman Pepper Hamilton Sanders
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions.... | Read More
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions. Her experience includes advising clients on partnership formation, operations and exit issues. She works with private equity funds to coordinate cross-border tax advice for structuring investments in a tax efficient manner. In addition, she counsels clients operating as partnerships, limited liability companies and S corporations on characterization of gain in an exit.Close
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.Close