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New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Implications for Existing and Future Partnership and LLC Agreements

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DESCRIPTION

Advisors to and clients in a partnership or limited liability company (“LLC”) structure should be aware that Congress has repealed the TEFRA partnership provisions and replaced it with a new IRS examination and tax collection regime.In light of the new legislation, advisors and clients should revisit their partnership and LLC agreements in order to bring those agreements into compliance and evaluate the rights and obligations of the partnership and its partners, or the LLC and its members, with regard to potential IRS examination and tax underpayment issues.

This new program from Bloomberg BNA, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Implications for Existing and Future Partnership and LLC Agreements, presented by Charles Ruchelman, Jonathan Brenner, and Rachel Partain, provides advisors and clients with an update on the new law, how it differs from the prior law, and issues to be aware of concerning revisions to current partnership and LLC agreements or drafting new agreements.

During this program, the speakers will cover:
• How the new rules are different from the old TEFRA rules.
• New “terms of art” and legal concepts to address or incorporate in partnership and LLC agreements.
• The power of the “partnership representative”.
• Opting “out” of the new partnership examination and collection regime and what it means.
• The IRS’s new methods of collecting underpayments of tax from the partnership.
• The obligations of current tax year partners if the IRS determines that there is a tax underpayment in a prior tax year.
• Discrete issues that might impact different types of businesses operating in partnership or LLC form, such as hedge funds, real estate investments, or private equity.
• The effective date of the new rules and how to prepare for the paradigm shift.

Educational Objectives:
• Prepare advisors, entities, and investors for the new tax laws relating to IRS examination and tax collection from partnerships and LLCs.
• Become conversant with the new legal terms and concepts in the new legislation.
• Identify and review the options for these entities with respect to selecting a “partnership representative” and options and opportunities for opting “out” of the new rules.

Who would benefit most from attending this program?
Legal and accounting advisories, corporate entities, and business investors

SPEAKERS

CHARLES M. RUCHELMAN, J.D., LL.M, CAPLIN & DRYSDALE, CHARTERED

Charles M. Ruchelman, J.D., LL.M. practices tax law in Washington, D.C. and is a Member of the law firm Caplin & Drysdale, Chartered.  Mr. Ruchelman was a trial attorney with the IRS Office of Chief Counsel and a trial attorney with the U.S. Department of Justice, Tax Division.  He is former chair of the D.C. Bar Tax Audits and Litigation Subcommittee.  Mr. Ruchelman’s practice frequently calls for application and analysis of the TEFRA partnership provisions in the examination, litigation, and collection contexts.


JONATHAN S. BRENNER, J.D., LL.M, CAPLIN & DRYSDALE, CHARTERED

Jonathan S. Brenner, J.D., LL.M. practices tax law in New York City and is a Member of the law firm Caplin & Drysdale, Chartered. A skilled legal practitioner with over 30 years of experience as a tax attorney and business adviser, Mr. Brenner counsels businesses and high-net-worth individuals on the most tax-efficient structures for their complex domestic and cross-border transactions.  Mr. Brenner brings to his practice a broad and deep understanding of the tax law, as well as the accounting, business, and legal issues that affect his clients' interests.  A substantial portion of his practice focuses on drafting partnership and LLC agreements for a wide-variety of business and investment entities.


RACHEL L. PARTAIN, J.D. LL.M., OF COUNSEL, CAPLIN & DRYSDALE, CHARTERED

Rachel L. Partain, J.D. LL.M. practices tax law in New York City and is currently Of Counsel with the law firm Caplin & Drysdale, Chartered.  Ms. Partain’s practice focuses on representing high-net-worth individuals, corporations, and TEFRA and other partnerships in complex federal and state tax controversy and litigation matters.  She has extensive experience on both the controversy and planning side of the practice of tax law with regard to tax issues involving partnerships and LLCs.