Video

  • 5 minutes

What Lead to the Bipartisan Budget Act of 2015

 
What led to the new partnership audit rules? Why is there a massive new regime for partnership audits? Congress’s motivation was to facilitate IRS audits and adjustments with respect to partnerships and LLCs taxed as partnerships, particularly tiered partnerships. They want consistent partnership reporting and auditing. There are potential increases in revenue with more streamlined, and thus potentially more frequent, audits of partnerships.

In this video our speakers, Kevin Spencer and Madeline Chiampou Tully, review motivations of Congress, problems with TEFRA, and how the new rules address and fix the TEFRA issues.

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: 4 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

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