MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak on BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successor Liability, and More
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Thursday, November 19, 2020
We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successor Liability, and More” on Tuesday, December 1, 2020, 10:00 a.m. – 11:30 a.m. (PST).
The IRS Large Business and International Division stated in its most recent Focus Guide that an increase in partnership audits is underway. Tax professionals must identify critical issues for partnerships subject to BBA audit rules and implement strategies for managing these audits and minimize potential tax liability and penalties.
The BBA centralized partnership audit regime replaced the Tax Equity and Fiscal Responsibility Act audit procedures and the electing large partnership rules. Under the BBA centralized partnership audit regime, the IRS generally assesses and collects any tax understatement at the partnership level. Under the BBA audit rules, many partnerships are subject to an entity-level audit by default.
A partnership is subject to BBA centralized partnership audit rules unless it is an eligible partnership and makes an annual election out of BBA on a timely filed Form 1065. An eligible partnership is one with 100 or fewer partners, all of whom are either individuals, C corporations or foreign entities treated as a C corporation if it were domestic, S corporations, or estates of deceased partners.
Listen as our panel of experienced tax attorneys discusses BBA audit procedures, recent IRS enforcement actions, and concrete suggestions on managing BBA audits, taxpayer rights, and other critical items.
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.
Please join us. For full programming details Click Here.
