Partnership Representatives: New IRS Final Regulations Under Section 6223 and Challenges for Pass-Through Entities
New Audit Procedures; Disregarded Entities as Partnership Representatives; Termination and Replacement
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will provide tax counsel and advisers guidance to the recently issued final regulations on the designation of partnership representatives for purposes of the centralized audit rules. The panel will discuss the new regulations under Section 6223 and the impact on pass-through entities, new IRS procedural and administrative processes for audits, the use of disregarded entities as representatives, notice requirements, and potential issues in maintaining compliance.
- Overview of the IRS partnership audit regime
- Selection and responsibility of partnership representives under Section 6223
- IRS final Section 6223 regulations
- Designating a disregarded entity as partnership representative
- Failure to designate an eligible party as partnership representative
- Terminating/replacing partnership representative
- Best practices and planning considerations for counsel in light of the final regulations
The panel will review these and other key concepts:
- What are the fundamental changes that the final regulations make in Section 6223?
- How does the change in the "capacity-to-act" provision impact the selection of partnership representative?
- Changes to the provision allowing the IRS to designate a representative if the partnership has not made an eligible selection
- How to change a partnership representative after the IRS has contacted a partnership about a possible audit?
- What are the rules governing the use of disregarded entities as partnership entities?
- Planning considerations for partnership agreements and transactions in light of the final regulations
Guinevere M. Moore
Ms. Moore serves as an attorney and a professional partnership representative to her clients. She has over a decade of... | Read More
Ms. Moore serves as an attorney and a professional partnership representative to her clients. She has over a decade of experience representing taxpayers in high stakes disputes with the IRS. She represents taxpayers before the IRS and in litigation before the United States Tax Court, United States District Courts, Courts of Appeals, and the United States Supreme Court. She particularly enjoys her client counseling role and advising clients on how to navigate a dispute with the IRS. Ms. Moore also serves as Executive Director at US Partnership Representative, Inc.Close
Rachel L. Partain
Caplin & Drysdale
Ms. Partain's practice focuses on representing high-net-worth individuals (HNWIs), corporations, and TEFRA and... | Read More
Ms. Partain's practice focuses on representing high-net-worth individuals (HNWIs), corporations, and TEFRA and other partnerships in complex federal and state tax controversy and litigation matters.Close