Tax Practice & Procedure | Partnership Examinations Under the New Rules
Federal Bar Association 2022 Tax Law Conference
Tax attorney Lee Meyercord will speak at the Federal Bar Association 2022 Tax Law Conference on "Tax Practice & Procedure | Partnership Examinations Under the New Rules." Congress enacted the partnership audit rules as part of the Bipartisan Budget Act of 2015 (BBA) to make it more efficient for the IRS to audit partnerships. At the time BBA was enacted, most partnerships were not subject to audit. The BBA rules generally went into effect in 2018 and the first IRS examinations under these rules began in 2019.
In October 2021 the IRS began its Large Partnership Compliance (LPC) initiative to examine large partnerships using data analytics and risk analysis similar to its program for examining large corporations. Also in October 2021, the IRS released Internal Revenue Manual procedures that govern BBA partnership audits. With the IRS’s increased emphasis on partnership audits, many partnerships may experience their first audit under these new rules soon. This panel will review the BBA examination process and discuss the implementation and scope of the LPC initiative. The panelists will also discuss the current IRS and practitioner experience in BBA audits and tips for familiarizing yourself for these types of audits.
- Review the examination process under BBA.
- Discuss the implementation and scope of large partnership compliance audits.
- Discuss the current experience to date from both the IRS and practitioner perspective.
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