Partnership Audit Adjustments Under the Centralized Audit Regime
Push-Out and Pull-In Adjustments, Audit Tips, and Forms 8978 and 8986
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will cover practical considerations for partners and advisers to partnerships operating under the new partnership audit regime. Our panel of experts will review the latest guidance, explain partnership audit adjustments, and recommend steps to implement this reporting regime.
Outline
- The centralized audit regime
- Electing out
- Partnership representatives
- Handling the audit
- Reporting
- Form 8978, Partner's Additional Reporting Year Tax
- Form 8986, Partner's Share of Adjustments to Partnership-Related Items
- Form 8979, Partnership Representative Revocation, Designation, and Resignation
- Form 8985, Pass-Through Statement--Transmittal/Partnership Adjustment Tracking Report
- Partnership agreements
Benefits
The panel will review these and other vital issues:
- Push-out adjustments
- Pull-in adjustments
- IRS forms for reporting audit adjustments
- Reviewing existing and considerations for new partnership agreements
- Recommendations for handling the IRS examination
Faculty
Robert Horwitz
Principal
Hochman Salkin Toscher Perez
Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil... | Read More
Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. Before entering private practice, he was a trial attorney in the U.S. Department of Justice Tax Division and the U.S. Attorney’s Office in Los Angeles, where he represented the United States in several hundred tax cases, involving areas as diverse as captive insurance companies, tax shelters, trust fund recovery penalties, manufacturers’ excise taxes, employment taxes, criminal investigations, and tax collection.
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Jonathan Kalinski
Principal
Hochman Salkin Toscher Perez
Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including... | Read More
Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters. Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel litigating Tax Court cases and advising revenue agents and revenue officers on a variety of complex tax matters.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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