Representing Partnerships in Tax Audits, Controversies and Litigation with the IRS

December 4, 2019 at 12:00pm4:45pmNext Month
American Law Institute Continuing Legal Education (ALI CLE)
Fox Rothschild LLP

2000 Market St.

20th Floor

Philadelphia, PA 19103

The new partnership audit rules represent the most substantial change to audits in almost four decades. Join Fox Rothschild’s International Taxation & Wealth Planning Practice Group Chair Jerald August for an ALI CLE program reviewing what the new rules look like in action – at formation, during the audit process and on appeal.

Also participating in this program will be attorney-advisers from the National Office of the IRS, as well as the Office of Chief Counsel, presenting their views on how the government should be expected to proceed, at the commencement of the partnership audit proceeding through trial, with respect to the “new” and “former” audit rules.

Topics will include:

  • Whether the partnership should and can elect out of the partnership audit rules
  • Selection of the partnership representative and contractual provisions related to the representative’s duties and responsibilities
  • Modifications to the imputed understatement amount
  • Benefits of the push-out and pull-in elections application to foreign partners and multitiered partnerships
  • Tax litigation alternatives arising from a partnership audit

Who Should Attend: Tax lawyers, business lawyers, in-house counsel, litigators, accountants and attorneys engaged in trust formation work.

This event is being presented live in Fox’s Philadelphia office and via webcast.

*Please note there is a cost to attend.