Video

  • 22 minutes

Partnership Audit Representative

 
The partnership must designate a partnership representative. This partnership representative has a much broader, much more powerful set of rights and obligations that you see in the tax matter regime. They have the sole authority to act on behalf of the partnership in an audit. The partnership and all partners are then bound by the decisions of the partnership representative. The partnership representative’s decisions are final with respect to the partnership. When working through the steps to designating this role you should think about applying significant checks and balances on the partnership representative in your partnership agreements. If you have concerns about any number of circumstances, you need to make sure the partnerships agreement also has verbiage giving partners some rights to consent agree with decisions of the partnership representative.

In this video our speakers, Kevin Spencer and Madeline Chiampou Tully, discuss tax matters partner vs. the partnership representative. They also review drafting points and provide sample drafting.

Kevin Spencer is a partner with McDermott Will & Emery and focuses his practice on tax controversy issues. He represents clients in complicated tax disputes in court and before the Internal Revenue Service at the IRS Appeals and Examination divisions. Mr. Spencer has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, among others.

Madeline Chiampou Tully is a partner with McDermott Will & Emery. She represents clients on federal income tax matters relating to taxable and tax-free mergers, acquisitions and divestitures, corporate restructurings and finance transactions; within these areas her tax practice focuses on energy tax issues, including advising on renewable energy transactions such as solar and wind projects.
Runtime: 21 minutes

Agenda

Faculty

Kevin Spencer

Kevin Spencer

McDermott Will & Emery

  • Partner with McDermott Will & Emery and focuses his practice on tax controversy issues
  • Represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions
  • Broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters
  • Prolific writer and lecturer on a variety of tax topics, and is an active member of the firm's Pro Bono and Community Service Committee
  • Adjunct law faculty member at Georgetown University Law Center and is an editor of the firm's Tax Controversy 360 blog
  • J.D. degree, cum laude, University of Miami School of Law; B.S. degree, cum laude, Mary Washington College, LLM degree, with distinction, Georgetown University Law Center

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today

Access to all training products $699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.