Learn about Centralized Partnership IRS Audit Rules, one of the biggest changes in history of partnership taxation. Partnerships will be taxed like C Corps if we don’t defend. **Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to firstname.lastname@example.org.
Not to get crushed by IRS collection of income tax from a partnership. How the tax preparer can decimate a partnership’s future (or save it). To avoid ugly partnership level income tax at highest rate (and perhaps no basis step up for partners). To protect clients by electing out of new regime - who, how, when and why. Congress’ Technical Corrections one month ago greatly expanded CPAR. To identify whether S corporations may look better than partnerships now. To lead your client to prepare in earnest today.
What is an “imputed underpayment” liability of a partnership? What is a “push out” election and how does a partnership get decimated without it? May a partner do the right thing and “amend out” or “pull in”? How must partnership/LLC operating, buy-sell, contribution, dissolution and loan agreements be revised to avoid problems? Who is a “partnership representative”? If we don’t choose one, IRS will for us (not even close to good).
Bradley P. Burnett is a tax accountant and attorney with an emphasis on tax planning and tax controversy. Prior to establishing a law firm in 1990, Burnett worked as a tax senior for a national CPA firm, tax manager for a local CPA firm, trust officer for a major bank, and managed the tax department as a partner in a medium-sized Denver law firm.
Burnett has delivered more than 650 presentations on tax law and tax planning to CPAs, attorneys, and civic groups throughout 46 states, Washington, D.C., and British Columbia. He has authored the texts of 12 full-day CLB/CPE courses, authored tax materials for Commerce Clearing House, and written various articles for tax journals and legal journals in the past 14 years.
After receiving his undergraduate degree in accounting and law degree, he earned a master’s in taxation from the University of Denver in 1984. Burnett has served as an adjunct professor at the University of Denver Graduate Tax Program.
Non-Member Price $129.00
Member Price $99.00