See Credit Details Below
Overview
Why You Should Attend
The Bipartisan Budget Act of 2015 (“BBA”) enacted partnership audit rules that adopt a radically different approach to the way adjustments are made in the partnership context. The partnership itself may be required to pay additional tax, but various partners may also be liable. This new program will focus on the unique procedural and strategic considerations for partnership audits under the BBA rules, addressing issues that are critical in transactions, audits, and administrative adjustment requests.
The faculty includes leading experts and senior government representatives who were involved in drafting the BBA regulations and are implementing the BBA procedures within the IRS. PLI is delighted to present this new program to help practitioners navigate this complex regime.
What You Will Learn
After completing this program, participants will be able to:
- Navigate the complex web of BBA procedures, understanding the different ways a partnership and its partners may be affected by an adjustment
- Properly identify the party bearing the risk of an adjustment and quantify that risk
- Draft BBA-related provisions in partnership agreements and other transactional documentation
- Identify BBA issues in transactional due diligence and structuring
Who Should Attend
This program is designed for tax attorneys, accountants and in-house tax professionals interested in understanding the BBA in IRS audits and the transactional context.
Program Level: Overview
Prerequisites: Interest in exploring the BBA partnership audit rules
Intended Audience: Attorneys, accountants and in-house tax professionals seeking a deeper understanding of the nuances of representing your clients in BBA partnership audits.
Advanced Preparation: None