Partnership Losses in Excess of Basis: Preparing for the IRS' New Audit Campaign
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will prepare pass-through advisors to withstand IRS challenges to partners' basis calculations. Our panel of federal tax experts will guide partners and tax professionals through the calculations necessary to determine a partner's basis in a partnership, the IRS examination, and handling prior period capital account errors.
Outline
- IRS' partnership basis compliance campaign
- Determining outside basis
- Tax basis capital
- Liabilities
- Section 743(b) basis adjustments
- Handling past errors
- BBA partnerships
- Amended returns
- Unresolved differences
- Handling the IRS examination
- Best practices
Benefits
The panel will cover these and other critical issues:
- How to maintain, calculate, and document basis by partner
- Tips for handling an IRS audit of a partner's basis
- How to appropriately resolve past capital account allocation errors
- How the new BBA partnership audit rules affect basis examinations
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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Cory Stigile
Principal
Hochman Salkin Toscher Perez
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation... | Read More
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
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