CPE Event Information

Objectives:  This course will address the most recent legislative changes, 2016 cases and 2016 rulings affecting LLCs and partnerships whatever they may be. The Bipartisan Budget Act of 2015 changed partnership audits forever.  TEFRA audit rules and electing large partnership rules are being repealed and replaced by NEW RULES that impose tax liability at audit at the partnership level for the first time ever.  Partners in a later year can bear the burden of disallowed deductions taken in earlier years by partners who have retired or sold their interests by the time of the audit.  The new rules generally apply to partnership tax years that begin after December 31, 2017. However, there is an election to apply the new rules for 2015 returns if the partnership elects.  So, you have no time to delay in getting up to speed on these major changes.  The Tax Matters Partner/Member is being replaced by a Partnership Representative that need not be a partner and can bind the partnership in audit.  Even the statute of limitations can go beyond three years. Expect new proposed regulations explaining the foregoing. Additionally, there are new proposed and final regulations under Section 706 addressing allocations when a partner’s interest changes mid-year, complex new proposed regulations dealing with hot assets, and proposed regulations on contributions of built-in loss property. Newly proposed regulations attacking discounts in family partnerships and LLCs.  

Prerequisite: None