Who do “Partnership Representatives” represent: the partnership, the general partner, the limited partners, or someone else? How can PRs carry out their responsibilities and wade through the numerous conflicting interests and privacy concerns in light of all the obligations and elections they may have under the new partnership audit rules, the partnership agreement, their own contracts with the partnership, fiduciary obligations, and most importantly, the professional responsibility and ethical rules? What do PRs have to think about and would you want to be one? Come and find out.
There are no handouts for this course.
Johnson Moore
Partner
guinevere.moore@jmtaxlitigation.com
(312) 549-9990
Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies. She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation. She is also the Executive Director of US Partnership Representative, Inc., and in that role she serves as a professional partnership representative.
Caplin & Drysdale
Member
crizek@capdale.com
(202) 862-8852
Christopher S. Rizek is a Member in Caplin & Drysdale's Washington, D.C., office. He also serves as General Counsel to the firm. Since 2013, The Legal 500 has listed Mr. Rizek as an elite "Leading Lawyer" for his contributions to tax controversy law.
IRS
Senior Level Counsel, Office of the Associate Chief Counsel (Passthroughs & Special Industries)
Clifford Warren is a Senior Level Counsel in the Office of Chief Counsel of the IRS, working in the Passthroughs group. Prior to joining the IRS, Cliff was head of tax at KKR. In addition, Cliff was head of tax at a large NYC hedge fund, the tax director of GE Capital Commercial Finance, and a tax lawyer at The Equitable. He is a graduate of Middlebury College, New York Law School and NYU School of Law (LLM Tax).
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