Partnership Examinations - WYNTK About New Partnership Procedural Rules 2023

This webinar will cover practical considerations for partners and advisers to partnerships operating under the new partnership audit regime. Our panel of experts will review the latest guidance, explain partnership audit adjustments, and make recommendations for steps to take in light of the implementation of this new regime.  The centralized partnership audit regime (CAR) is effective now. The Bipartisan Budget Act of 2015 (BBA) included a new audit regime for partnerships effective for audits of partnership returns for years beginning in 2018. Under the new rules, the partnership itself remits the underpayment (or receives the overpayment) resulting from an IRS examination at the end of an IRS review and pays the additional tax due at the highest income tax rate available (37% currently). Alternatives include making a push-out election taxing the individual partners owning interests during the year examined and showing that partners have amended their returns to account for the adjustments, the amended return adjustment. The Corrections Act in 2018 reduced the burden of filing amended returns by allowing partners to pay the amount of tax due and adjust any related tax attributes without the burden of filing amended tax returns, the pull-in procedure.