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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Michel Stein , Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Partnership Audit Adjustments Under the Centralized Audit Regime,” Wednesday, October 19, 2022, 10:00 a.m. – 11:30 a.m. (PST).

This course 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 recommend steps to implement this reporting regime.

IRS audits are taking place under the Bipartisan Budget Act’s new audit regime, and tax professionals are wrestling with the complexities of the new requirements. Under these rules, the partnership itself remits any underpayment resulting from an IRS examination at the end of an IRS review. It pays the additional tax due at the highest income tax rate (37 percent currently).

Alternatives include making a push-out election taxing the individual partners’ interests during the year examined and showing that partners have amended their returns to account for the adjustments. 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 limitation of filing amended tax returns, the pull-in procedure.

The reporting regime includes Form 8986, Partner’s Share of Adjustments to Partnership-Related Items, and Form 8978, Partner’s Additional Reporting Year Tax. Partners receiving Form 8986 must file Form 8978 to report additional tax due as a result of examination adjustments. Multiple forms may be obtained, covering changes for different years, and these adjustments could be both negative and positive.

The rules are so complex that the AICPA recommended a new form AAR-EZ to simplify the reporting process.

Listen as our panel of experts explains the ins and outs of audits under BBA, including making push-out and pull-in adjustments, electing out, and best practices for handling the audit.

We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com. 

Click Here for more information.

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