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Partnership Examinations - WYNTK About New Partnership Procedural Rules 2023

May 23, 2023 | 9–10 a.m. PT

CPE: 1
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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. 

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  • Credit Type
    CPE: 1
    CPE-Technical: 1
    IRS-TX: 1
    MCLE: 1
    MCLE LS-TX: 1
  • Intended Audience

    CPAs, financial advisors, and lawyers

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  • Advance Preparation


Learning Objectives

Identify Push-out and Pull-in adjustments

Understand new IRS forms for reporting audit adjustments

Identify existing and new considerations for new partnership agreements

Determine recommendations for handling the IRS examination

Major Subjects

  • The centralized audit regime
  • Electing out
  • Partnership representatives
  • Handling the audit
  • New forms
  • Form 8978, Partner's Additional Reporting Year Tax
  • Form 8986, Partner's Share of Adjustments to Partnership-Related Items
  • Form 8979, Partnership Representative Revocation, Designation, and Resignation
  • Form 8985, Pass-Through Statement--Transmittal/Partnership Adjustment Tracking Report
  • Partnership agreements