Learn to identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions.
In 2015, Congress passed the Bipartisan Budget Act of 2015 (the BBA), which completely changed the way partnerships (and entities treated as partnerships) were audited and assessed tax by the IRS. The Department of Treasury and the IRS have issued guidance implementing the new audit procedures in the BBA, and these procedures generally are effective for taxable years beginning after December 31, 2018. This topic will help the persons responsible for the tax functions of partnerships understand the new partnership audit regime and the key differences from the old partnership audit regime, commonly known as TEFRA. The information will also help identify unique issues posed by the new partnership audit rules in the context of partnership formation and acquisitive transactions involving partnerships.
Agenda
Faculty
Matt Donnelly
Baker Botts L.L.P.
- Special counsel with Baker Botts L.L.P. in Washington, D.C.
- Focuses his practice on U.S., federal income tax matters with a concentration on domestic and international mergers and acquisitions, dispositions, spin-offs, joint ventures, financing transactions (including tax-incentivized renewable energy financing transactions), restructurings, and internal reorganizations
- His clients include both public and private companies
- An adjunct professor at Georgetown University Law Center and Howard University School of Law, teaching courses on transactional tax issues and corporate taxation
- Frequently writes and lectures on tax-related topics, including transaction structuring, spin-offs and Reverse Morris Trust transactions, renewable energy tax incentives, partnership taxation, and the impacts of tax reform
- Can be contacted at 202-639-7875 or [email protected]
Peter Farrell
Baker Botts L.L.P.
- Special Counsel with Baker Botts L.L.P. in Washington, D.C.
- Focuses his practice on U.S., federal income tax matters with a concentration on tax-efficient structures for domestic and international mergers, acquisitions, joint ventures, separations, restructurings, and other reorganizations
- Clients include both public and private companies
- Frequently writes and gives talks on tax-related topics, including transaction structuring, spin-offs, reorganization transactions, renewable energy tax incentives, and the new and pending legislation affecting corporations and passthrough entities
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