Remedies for Partnership Form 1065 Errors Resulting from Tax Reform and Centralized Audit Rules

Fixing Missed or Incorrect Elections, Superseding Returns, Change of Partnership Representative, Tax Basis Reporting

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A


Conducted on Wednesday, October 30, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar will provide tax professionals and advisers with a critical early look at available measures to correct errors on Form 1065 U.S. Return of Partnership Income arising from specific provisions of the 2017 tax reform law. The panel will focus on the recent IRS guidance allowing certain partnerships to file superseding 1065 returns and will discuss situations where IRS guidance issued after the filing of the original return necessitates corrections. The webinar will also outline available elections and relief requests.

Description

Practitioners continue to wrestle with 2017 tax reform and evolving IRS guidance in the wake of massive changes to partnership taxation and a new centralized partnership audit regime. Tax advisers and compliance professionals serving partnerships now face the task of determining whether the first years' tax returns filed after the new law are compliant.

Beyond the complex new 199A provisions, partnership and LLC entities also are faced with significant new calculations, interest limitations, tax basis disclosures, and partnership audit rules. Partnership tax advisers should review the first two years' filings to protect pass-through clients from errors and miscalculations.

The new rules prohibit partnerships from filing amended returns for the current tax year. However, the Code provides several avenues for correcting Form 1065 errors. The IRS, recognizing the likelihood of incorrect partnership filings, recently issued Rev. Proc. 2019-32, extending the timeline for filing superseding returns for the 2018 tax year for certain partnerships.

Listen as our experienced panel provides a critical first look at available elections and relief provisions to correct errors on partnership tax returns resulting from the new tax law and centralized audit regime.

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Outline

  1. Partnership reporting errors arising from the tax reform law
    1. Incorrect partnership representative designation
    2. Opt-out election from centralized audit regime for eligible partnerships
    3. 199A calculation and aggregation errors
    4. Partners' tax basis K-1 disclosure errors
  2. Impact of errors on book accounting and corrective entries
  3. Rev. Proc. 2019-32 extending deadline for superseding returns
    1. Eligible partnerships
    2. Filing deadlines
    3. Reissuing K-1s
  4. Corrective elections
  5. Other avenues for relief from penalties due to Form 1065 errors

Benefits

The panel will address these and other relevant questions:

  • IRS proposed and temporary guidance on how the 20% deduction for qualified business pass-through income works
  • Critical provisions and changes in the new tax reform law for partnerships and LLCs
  • How changes to other business tax provisions impacted partnerships and other pass-through entities
  • Discussion of interest and loss limitations
  • Planning considerations in light of Dec. 31, 2025, sunset provision

Faculty

Coppinger, Terence
Terence Coppinger

Partner
Mazars USA

Mr. Coppinger has been advising clients in the areas of tax information reporting and IRS practice and procedure for...  |  Read More

Tannenbaum, Faye
Faye Tannenbaum, CPA

Partner
Mazars USA

Ms. Tannenbaum has over 28 years of experience providing tax compliance and consulting services to some of the largest...  |  Read More

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