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Tips for Handling Audits of Pass-Through Entities Under the Centralized Partnership Audit Regime

TIPS FOR HANDLING AUDITS OF PASS-THROUGH ENTITIES

Cost $30.00
Presentation Length 1.0 hour

Recorded DateJune 24, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-border activities, and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships that elect out of the centralized audit regime, the IRS will have to audit, assess, and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.

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Megan L. Brackney concentrates her practice in the areas of civil and criminal tax controversies.  Ms. Brackney received her J.D. from the University of Kansas School of Law and her LL.M. in Taxation from New York University.  Ms. Brackney teaches Tax Procedure as an adjunct professor at New York University.  Ms. Brackney is a former Vice Chair of Committee Operations for the American Bar Association Section of Taxation, a member of the New York State Bar Association Tax Section’s Executive Committee, and a Fellow of the American College of Tax Counsel.  Ms. Brackney annually contributes to the two-volume ABA publication, Effectively Representing Your Client Before the IRS, and serves on the editorial board of the The Tax Lawyer.  Ms. Brackney has been recognized by New York Super Lawyers” and “Best Lawyers in America,” and Chambers USA has ranked Ms. Brackney as a leader in Tax Controversy.  

About Our Presenter

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For nearly 85 years, the NYU School of Professional Studies has been a deeply respected institution of higher education grounded in applied learning. It has served as a source of empowerment for individuals from NYC, across the country, and worldwide who aspire to become the next generation of leaders and innovators of industry.

Throughout its rich history, NYUSPS has met the needs of the students and the professional communities it serves. From its early years of training returning World War II veterans to fulfill the nation’s urgent need for skilled technical workers, it has evolved into a professional education powerhouse that offers 19 graduate degrees, 13 bachelor’s degrees, four associate’s degrees, and a plethora of non-degree courses