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IRS Partnership Audit Rules for Tax Counsel: Partnership Agreement Drafting Considerations, Transfers, and More

October 24, 2023 at 1:00pm2:30pm (EDT)

Attorneys Leah Segal and Andria Williams provide a critical analysis of the impact of the partnership audit rules on the operations, transactions, and other aspects of partnerships. This CLE/CPE webinar will provide tax counsel with an up-to-date look at the drafting, commercial, and compliance implications of the partnership audit rules, including a discussion of recent IRS enforcement actions. The panel will describe the partnership audit processes in detail, outlining the key items that facilitate IRS audits of partnerships. They will offer concrete suggestions on partnership agreement drafting provisions and other changes to partnership operations in accordance with the audit processes.

Attendees will come away with a greater understanding of the following:

  • How the entity-level change facilitates IRS audits
  • Elimination of concept of "tax matters partner" and requirement of "tax representative" with authority to represent the partnership in an audit
  • Commercial and transactional issues arising from the partnership audit rules
  • Drafting and amending partnership agreements