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ROBERT HORWITZ, CORY STIGILE and PHILIPP BEHRENDT to Speak at Upcoming Strafford Webinar

We are pleased to announce that Robert Horwitz, Cory Stigile and Philipp Behrendt will be speaking at the upcoming Strafford webinar “Partnership Losses in Excess of Basis: Preparing for the IRS Audit Campaign, Tuesday, June 20, 2023, 10:00 a.m. – 11:50 p.m. (PST).

In February 2022, the IRS announced a partnership campaign to include audits of partners’ deductions of flow-through losses from partnerships. The Service believes that partners are deducting losses in excess of basis rather than suspending these losses when required. The IRS heightened its ability to track partners’ capital by implementing requirements to report negative tax basis capital in 2019, all partners’ capital accounts beginning in 2020, and added disclosures for Section 704(c) built-in gains and losses. The IRS is using data analytics to identify partnerships that are most likely noncompliant.

Practitioners who have been scrambling to meet these added reporting requirements must prepare to defend these positions and the calculations reported. Determining a partner’s outside basis, including whether tax basis capital has been appropriately captured and a partner’s share of liabilities, is complicated. Recent reporting rules have led to the discovery of allocation errors.

Pass-through entity advisers need to prepare for upcoming examinations and know how to handle audits of pass-through entities.  Listen as our panel of IRS partnership examination experts explains how to properly maintain and support partners’ basis in partnerships and how to defend these calculations when representing partners.

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