Partnership Audit Regulations: What Every Lawyer Needs to Know

In 2017, the IRS issued new regulations that implement a centralized audit regime for partnerships. The new audit regime, which takes effect January 1, 2018, is designed to raise tax revenue and make it easier for the IRS to audit large partnerships, and allows the IRS to collect tax directly at the entity level from the partnership.

This program, taught by Vivek Chandrasekhar of Roberts & Holland and Sarah Brodie of Morgan Lewis, will discuss the background of the new Partnership Audit rules, the changes in tax liability for partnership entities, and what attorneys need to know about drafting operating agreements to best serve their clients under the new regime.

Learning Objectives:

1. Survey the history of the Partnership Audit Rule in the context of its precursor
2. Discuss what the changes will mean for partnership entities in 2018
3. Draft operating agreements addressing these changes