Video

  • 34 minutes

Partnership Audits - Elections

 
IRC Section 6221(b) is an exception to the default rule of entity level tax which is really focused on small partnerships. It’s an election that is filed year by year with the partnership’s tax return. The election is only available to partnerships that issue 100 or less K-1s in a taxable year. There are special rules for counting partners, not just anybody who is a partner counts as these rules are trying to avoid tiered partnerships. Each partner needs to be either an individual, a C corporation, an S corporation, etc.… and the partnership must notify all partners of the election out.

In this video our speakers, Kevin Spencer and Madeline Chiampou Tully, review election out drafting points and sample drafting. They also discuss the push-out election including reporting adjustments, uncertainties, and factors to consider in making the election. Mr. Spencer and Ms. Tully also cover no push-out election and election in.

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: 33 minutes

Faculty

Kevin Spencer

Kevin Spencer

McDermott Will & Emery

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

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