IRS Partnership Audit Rules for Private Equity and Hedge Funds
Tax attorneys Mary McNulty and Lee Meyercord will present a Strafford CLE webinar that will examine the IRS partnership audit rules and their impact on private equity and investment funds. Ms. McNulty and Ms. Meyercord will also discuss the provisions for partnership and LLC agreements in contemplation of the new rules, the elections available to smaller partnerships to avoid the partnership level audits and "push-out" elections that allow for changes in ownership.
- The Bipartisan Budget Act of 2015 and phase-in of the partnership audit rules
- Exceptions and opt-out rules
- Implications of partnership level tax vs. individual partner level tax
- Issues for private equity and other investment funds
- Partnership representative: new final regulations issued under Section 6223
- Suggested amendments to an existing partnership or LLC agreements