the New Partnership Audit Regime 2017 - CALT Audit Issues...The New Partnership Audit Regime October...

10/19/2017

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Center for Agricultural Law & Taxation

The New Partnership Audit Regime

October 19, 2017


Small Partnerships – Current Rules

• Partnership audits with 10 or fewer qualified partners (e.g., no flow through entities, like LLCs, as partners) are conducted at the partner level (unless the partnership elects to be audited under TEFRA)

• The IRS examines the partnership’s return, but audit determinations are ultimately made at the partner level

• Each partner has the right to participate in his or her specific audit

• The IRS makes adjustments to each partner’s return

• At the conclusion of the audit, the IRS will issue a separate notice of deficiency to each partner

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Medium and Large Partnerships – Current Rules

• Partnership audits with 11 or more partners (or fewer partners, if there is a nonqualified partner such as an LLC) are audited under the TEFRA rules

• If there are adjustments, TEFRA allows the IRS to conduct one audit (at the partnership‐entity level) and issue one notice (a Final Partnership Administrative Adjustment or FPAA) to the partnership (and copies to certain “notice” partners)

• TEFRA also allows the IRS to deal with a single tax matters partner (TMP) who can bind all the partners (although partners may have the right to participate in administrative or judicial proceedings)

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Large Partnerships – Current Rules

• Large partnerships, with at least 100 partners, have the option to elect the Electing Large Partnership (ELP rules)

• However, these rules provide less participation rights under TEFRA and are rarely elected

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Reasons for Change

• The TEFRA rules for auditing partnerships were enacted in 1982

• It made it easier for IRS to audit the mass‐marketed tax shelter partnerships

• After the adoption of the passive activity loss rules these generally disappeared

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A Bit of History

• In the last 20 years partnership has show substantial growth in the number and size of large partnerships

• This has presented challenges to the IRS's ability to audit these entities

• In 1997, to address the complexity of the TEFRA rules and Congress created an elective regime (ELP‐Large Partnerships) allowing partnerships with 100 or more partners to pay tax, interest, and penalties on adjustments to the partnership return

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Elective Regime

• In 2013, only 91 of the 10,948 partnerships with more than 100 partners had elected these rules

• In July 2014, the U.S. Government Accountability Office (GAO) reported that the number of large partnerships (defined as those with at least $100 million in assets and at least 100 direct or indirect partners) more than tripled from 2002 to 2011

• Only 0.8% of such entities were audited by the IRS, compared with 27.1% of comparable large corporations

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The Proposed Fix

• H.R. 2821, the Partnership Audit Simplification Act of 2015 was introduced in 2014

• The bill, with substantial modification, became the basis of the new partnership audit rules adopted by the Budget Act

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The Plan that Was Adopted – History First

• The Budget Bipartisan Act was enacted on November 2, 2015

• It was then amended by the Protecting Americans from Tax Hikes Act of 2015 – December 18, 2015

• TEFRA addressed a problem of applying partnership adjustments to multiple partners in separate proceedings by specifying that the tax treatment of "partnership items"

• Fresh controversies erupted over defining and clarifying which items were partnership items and which were partner‐level items 9


TEFRA

• The Budget Act dispensed with the partnership‐item criterion in favor of determining any adjustment to items of income, gain, loss, deduction, or credit of all partnerships at the partnership level, with the partnership, rather than partners, generally liable for any resulting imputed underpayment

• However, in certain cases partnerships will be able to elect out of the new rules

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Summary

• The Bipartisan Budget Act of 2015 replaced the TEFRA partnership audit rules with new procedures effective for partnership years beginning after 2017

• In addition an option was provided for partnerships to adopt them for years beginning after their enactment in November 2015 was provided

• Generally, the new rules require adjustment of all items of income, gain, loss, deduction, or credit at the partnership level, with the partnership liable for any resulting underpayment of tax

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Why Should You be Concerned about the New Rules?

• Any audit that will occur at the partnership level:

• All adjustments will be calculated by reference to the partnership (and not the partners)

• All payments resulting from an audit will be made by the partnership

• Partners will have no information or participation rights in respect of the audit

• Given the simplified process, audit rates for partnerships are expected to increase

• In addition, many states are considering changes to their own partnership audit rules

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Review Year and Adjustment Year

• Under these audit rules, the IRS will examine partnership items for a particular year, the “reviewed year”, and any adjustments will be taken into account by the partnership at the partnership level in the year the audit or judicial review is completed the “adjustment year”

• This is a significant change from the current TEFRA provisions as it shifts the cost of any adjustment to the partners/partnership in the adjustment year rather than flowing the adjustments through to the partners/partnership who may have benefitted in the reviewed years

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The Assessment

• The partnership will pay the tax, interest, and penalties on underpayments

• The tax due is calculated by multiplying the net of the adjustments by the highest statutory corporate or individual rate in place

• Any adjustments not causing underpayments will then flow through to the partners in the year of the adjustment

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The Assessment

• The amount of the underpayment at the partnership level could be reduced by:

• The tax reported on the underpayment by partners filing amended returns

• The tax attributable to tax‐exempt partners, and

• The tax rate differential due to a lower corporate tax rate or lower capital gain/dividend rate

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Imputed Underpayment

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Calculation of the Imputed Underpayment

• The imputed underpayment will be equal to the:

• “Total netted partnership adjustment”

• Multiplied by the highest federal income tax rate

• What is difficult is how is the “total netted partnership adjustment” arrived at?

• The process relies on the grouping and netting rules

• Three main groups

• The “reallocation grouping”

• The “credit grouping”

• The “residual grouping” 17


Fourth Group

• “Creditable Expenditure Grouping”

• These are expenditures are those reflected on the partnership return for which credits are separately calculated on the tax returns of the partners

• This is a “reserved group” – may not apply to all and is part of the “Credit Grouping”

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Calculation of the Imputed Underpayment – The Process

• Ensure income and loss only offset one another to the extent that they are the same character

• Ensure the changes in allocations from one partner to another do not off set each other

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Reallocation Group

• Partnership adjustment that reallocates a distributive share of an item of income

• Possibly a reallocate from one partner to another

• Income to partner A really belongs to partner B

• Any adjustment not assigned to the “reallocation group” or the “credit group” ends up in the “residual group”

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Groups Are Then Divided into “Sub‐Groups”

• Reallocation grouping – divided into each adjustment for a particular partner

• In the “residual grouping” these is a group to establish an “account for limitations or restrictions such as character and holding period

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Once Grouped – Netting Occurs

• Any adjustment that increases gain will be treated as an increase in income

• Any adjustment that decreases gain will be treated as a decrease in income

• Any adjustment that increases loss will be treated as a decrease in income

• Any adjustment that decreases loss will be treated as a increase of income

• Determine: Net positive adjustment or a net negative adjustment – “Total netted partnership adjustment” 22

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“Specific Imputed Underpayment”

• Allocation to a specific group of partners

• Separate liability

• Example 3• Partnership has two partners, A and B

• Under the partnership agreement, among other items allocated to the partners, $30 of ordinary income and $70 of depreciation are specially allocated to B for the 2019 taxable year

• In an administrative proceeding with respect to Partnership’s 2019 taxable year, the IRS determines that the $30 of ordinary income and $70 of deprecation should be reallocated from B to A

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• The partnership adjustment is a decrease of $30 of ordinary income (<$30> adjustment) and a decrease of $70 of depreciation ($70 adjustment) allocated to B and a corresponding increase of $30 ordinary income ($30 adjustment) and $70 of depreciation (<$70> adjustment) allocated to A

• For purposes of determining the imputed underpayment, the adjustments to the distributive shares of A and B are grouped separately

• The increases and decreases to depreciation are treated as decreases and increases, respectively, of ordinary income

• As a result, the net $40 of income ($70 ordinary income plus <$30> ordinary income) allocated to B is the total netted partnership adjustment

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• The $40 increase is then multiplied by 40 percent, which results in an imputed underpayment of $28

• The net decrease of income of $40 ($30 ordinary income plus <$70> ordinary income) reallocated to A is disregarded for purposes of determining the imputed underpayment

• The $30 of ordinary income and the $70 of deductions reallocated to A are partnership adjustments that do not result in an imputed underpayment

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Electing Out

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Electing Out of the New Rules

• While the new audit and adjustment rules apply to all partnerships for tax years after 2017, certain partnerships will be able to elect out of the regime

• Under the election out any adjustment to partnership taxable income will flow through to the partners with the assessment of tax

• Similarly, partners will make any extension of a statute of limitation, settlement agreement, notice of deficiency, petition to the Tax Court, or suit for a refund individually on a partner‐by‐partner basis

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Electing Out of the New Rules

• Since this is an annual election, a partnership may elect out in some years and not in other years

• A partnership may elect out, under procedures to be issued, for a year if:

• The partnership is required to issue no more than 100 Schedules K‐1, Partner's Share of Income, Deductions, Credits, etc., to its partners

• Each partner is an individual, an estate of a deceased partner, an S corporation, a C corporation, or a foreign entity that would be treated as a C corporation if it were domestic

•

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Electing Out

• Thus, a partnership that has as a partner that is a partnership or a trust, including a grantor trust, may not elect out

• Any partnership with a tax‐exempt organization as a partner will need to determine whether the entity is a C corporation or trust for purposes of eligibility to elect out

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“§ 6221 Election” (Electing Out)

• The “§ 6221 election” suggests that partnerships simplify their ownership structure (e.g. no LLCs or trusts) and to provide the IRS with the tools they will need to track down the partners who will be required to pay the tax

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Eligible Partner

• The proposed regulations define the term “eligible partner” as any person who is an individual, C corporation, eligible foreign entity, S corporation, or an estate of a deceased partner

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S Corporation

• Where an S corporation is a partner:

• The names and taxpayer identification numbers of the S corporation's shareholders must be included with the election statement, and

• The Schedules K‐1, Shareholder's Share of Income, Deductions, Credits, etc., of the S corporation's shareholders (as well as the S corporation itself) count in measuring the 100‐partner limit

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Example from the Regulations

• During its 2020 taxable year, Partnership A has 51 partners ‐ 50 partners who are individuals and S, an S corporation

• S and Partnership are both calendar year taxpayers

• S has 50 shareholders during the 2020 taxable year

• Under § 6031(b), Partnership A is required to furnish 51 statements for the 2020 taxable year – one to S and one to each of Partnership’s 50 partners who are individuals

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Example from the Regulations – Cont’d

• Under § 6037(b), S is required to furnish a statement (Schedule K‐1 (Form 1120‐S), Shareholder’s Share of Income, Deductions, Credits, etc.) to each of its 50 shareholders

• The number of statements required to be furnished by S per §6037(b), which is 50, is considered to determine whether partnership has 100 or fewer partners

• Accordingly, Partnership has a total of 101 partners (51 statements furnished by Partnership to its partners plus 50 statements furnished by S to its shareholders) and is therefore not an eligible to “opt‐out” of the centralized partnership regime

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Making the Election

• An election is filed with a timely filed (including extensions) return identifying the names and identification numbers of the partners and

• The partnership notifies each partner of the election within 30 days of making the election

• Election must include:

• Names and correct TIN’s of all partners

• Federal classification of all partners of the partnership

• Same applies to S Corporation shareholders

• Example on page 168 of the regulations35


Push Out Election

§6226

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Electing Out ‐ The § 6226 (“the Alternative”) Election – Push‐Out Option

• New § 6226 allows the partnership to elect that all the partners from the audited year pay the tax underpayment

• The election must be made within 45 days from the date of the notice of final partnership adjustment

• The “§ 6226 election,” the partnership must issue a statement of the partner’s share of adjustment to income, gain, loss, deduction, or credit (i.e., adjusted Schedule K‐1) to the IRS and to each partner of the audited year (or partnership taxable year, under audit, to which the item being adjusted relates)

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Electing Out ‐ The § 6226 (“the Alternative”) Election

• Each of these partners is required to pay the adjusted tax with their current return determined by the calendar year the adjusted K‐1 is issued

• Notice that, under the alternative election:

• The IRS still does not need to chase the separate partners

• The responsibility is on the partnership to identify and to ensure that each partner of the audited year pays the tax underpayment

• The adjusted Schedule K‐1 is included with each partner’s return for the year it is issued and not for the audited year

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Six Types of Modifications

• Amended returns

• Modifications attributable to tax exempt partners

• Modifications to an applicable tax rate – like capital gains/ordinary income

• Modifications to take into account certain passive lossesof publicly traded partnerships

• Modifications of the number and composition of imputed underpayments

• Modifications based on dividends distributed by apartner that is a regulated investment company or real estate investment trust 39


§ 6225 (“Lower the Imputed Tax”) Option

• What if a partnership is ineligible to elect out or does not want to simplify itself?

• What if the partners from the audited years refuse to cooperate?

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Reminder

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• New § 6225(c) requires the IRS to take into account the correct tax liability of the partners (when computing the imputed tax underpayment) where:

• At least one partner from the audited year files an amended return consistent with the adjustments and pays the tax in full

• At least one partner from the audited year is tax exempt; or

• A lower rate should apply because the partner is a C‐Corporation or because the adjustment is made to a qualified dividend or a capital gain

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• The “§ 6225 option” is not a removal from the new rules – as any imputed tax underpayment can still be collected from the partnership

• But it offers some relief to partnerships unable or unwilling to make the §§ 6221 or 6226 elections, from being taxed at the highest individual rate of 39.6 percent

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Example 1

• Ashworth Partnership a qualified small partnership elected out of the BBA rules, when it timely filed its 2018 return (and Schedule K‐1s), and it provided the required partner information to the IRS

• In addition, they notified both partners of the § 6221 election

• IRS will need to follow the old (or current 2017) audit rules

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Example 1 Cont’d

• The IRS will make the partnership adjustments, through separate audits of each partners’ individual returns (Form 1040s), and issue a separate notice of deficiency to each partner

• Finally, IRS will assess and collect any tax underpayment directly from the partners

• Notice that none of the new BBA rules apply

• The partnership is a small and simple partnership that made an election prior to the audit

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Example 2

• Each member of the S‐Corporation counts as one partner, and the maximum number of Schedule K‐1s that a partnership can issue to qualify for the § 6221 election is 100

• With a total of 101 Schedule K‐1s (100 members in the S‐Corporation and one individual), the Olsen Partnership does not qualify to elect out of the BBA rules

• Therefore, the BBA rules will apply to the audit of the partnership return

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Example 2 Cont’d

• The IRS will audit the Olsen Partnership return at the entity level and make any adjustments to its return, through a single Final Partnership Adjustment (FPA)

• However within 45 days of receiving the FPA, the Olsen Partnership makes a § 6226 election

• They issue adjusted Schedule K‐1s to the IRS and to the 2018 partners reflecting changes in their distributive shares consistent with the FPA

• Also each 2018 partner agreed to pay any resulting underpayments in full (with interest and penalties) with their 2020 returns 47


Example 2 Cont’d

• IRS collection would not assess the Olsen Partnership

• Unlike the Ashworth Partnership, the Olsen Partnership undergoes an audit incorporating the new rules, because the § 6226 election was made at the end of the audit

• Please note that when making this election, the adjusted Schedule K‐1 is included with each partner’s return for the year it is issued (2020) and not for the audited year (2018)

• The IRS will, generally, have at least three years from the date the partner’s 2020 return is filed to review the partners return and make sure the new distributive share (resulting from the FPA) was properly reported

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Example 3

• Mixup Partnership’s structure is complex, as one of its partners is an LLC

• The BBA audit rules automatically apply

• The IRS will audit the Mixup Partnership, at the partnership level, and make any adjustments through an FPA

• The Mixup Partnership did not make a §6226 election

• IRS will follow the new default collection rules

• The IRS will assess and collect the imputed tax underpayment directly from the partnership – at the highest individual or corporate tax rate

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Example 3 – Cont’d

• § 6225(c) requires the IRS to take into account the correct tax liability of the partners when, one partner is tax exempt

• Fortunately, one of the Mixup Partnership’s equal partners is a tax‐exempt corporation

• The Mixup Partnership can contend that 50 percent of the imputed tax underpayment is allocable to a partner that does not owe tax

• Therefore, the highest rate should, accordingly, be reduced (the § 6225 option)

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Treatment

• If partners do not treat all items of income, etc., consistent with the treatment on the partnership return, the IRS may collect a resulting underpayment under its math or clerical error authority without resort to traditional audit procedures, including issuance of a deficiency notice.

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Imputed Underpayment

• The imputed underpayment is calculated by multiplying the total netted partnership adjustment by the highest rate of federal income tax in effect for the reviewed year

• The product of that amount is then increased or decreased by any adjustment made to the partnership’s credits

• If the result of this summation is a net positive adjustment, the resulting amount is the imputed underpayment, and, if it is a net negative amount, there is no imputed underpayment

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The Imputed Under Payment

• Aa partnership's net adjustments for the reviewed year (the imputed underpayment) will be taxed at the highest individual or corporate tax rate

• Additional taxes, as well as penalties and interest, arising from an audit are payable by the partnership

• However, remember that the partnership may elect to pass through to its partners their respective shares of the adjustment, with the partners paying tax, penalties, and interest on their adjusted distributive shares

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Partnership Agreement

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Partnership Agreements

• Partnerships should amend their partnership agreements

• Partnership agreements should be reviewed and revised to account for the new partnership representative requirements

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Partnership Agreement

• The partnership agreement may require the partnership representative to provide notice of audit proceedings

• Require that the partnership representative obtain a partner vote, or

• Restrict the activities of the partnership representative

• The partnership representative’s act or failure to act will be binding on the partnership

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Statutes of Limitations

• The statute of limitations for assessments is determined based upon when the partnership’s return was filed and considers extensions between the IRS and the partnership, rather than taking into account partners’ individual assessment statutes of limitations

• The statute of limitations for filing partnership refund claims is based solely on when the partnership return was filed, and cannot be extended by agreement

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Partnership Representative

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Control of the Audit – Partnership Representative

• The partnership must designate a “partnership representative” on each of the partnership’s U.S. federal income tax returns

• The designated partnership representative controls the audit and, by law, is the only person allowed to work with the IRS

• If the partnership representative is an entity, an individual must also be appointed to serve as the “designated individual,” the only person authorized to deal with the IRS in regard to an audit of that tax year

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Control of the Audit – Partnership Representative• The IRS has not yet indicated how a designated individual will be

appointed, i.e., on the partnership’s annual tax return or otherwise

• The draft below still contains the TMP information

• The partnership representative (or designated individual, as applicable) does not have to be a partner in the partnership

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• The law provides the partnership representative (and any designated individual) has full control of all the partnership audit proceedings with the IRS (partners may not participate)

• There is no requirement that the IRS inform the partners of audit proceedings

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Removal of Partnership Representative

• The Proposed Treasury Regulations provide for the partnership to remove a partnership representative in certain circumstances

• But, the language regarding a partnership’s or a partnership representative’s removal of a designated individual has not yet been released

• IRS will deal only with the partnership representative

• Failure to appoint a partnership representative is vital as failure to do so will result in an appointment by the IRS

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• The partnership representative and any designated individual must have a “substantial presence” in the United States,

• Determined by having a U.S. postal address

• Telephone number, and

• Taxpayer identification number

• The partnership representative must also be able to physically meet with an IRS representative at the IRS’s discretion

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Consistency Requirement

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• § 6222 generally requires partners to treat partnership items on their returns in a manner that is consistent with the partnership’s treatment of such items

• A partner’s deviation from the partnership’s treatment of an item is treated as if it were a math error on the partner’s return

• However, a partner may report an item in a manner that is not consistent with the partnership’s reporting if the partner files a statement with the IRS identifying such inconsistency

• .

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• The consistency requirements apply to a partner that is itself a partnership (upper‐tier partnership), regardless of whether the upper‐tier partnership elected out of the BBA rules

• Any inconsistent treatment of a lower‐tier partnership item on the upper‐tier partnership’s return would be treated as a math error and the abatement procedures of § 6213(b)(2) would not be applicable

• Procedures for a partner receiving incorrect information from a partnership is included in the regulations allowing the partner to demonstrate that the treatment of the item on the partner’s return is consistent with the treatment of that item on the statement or schedule furnished to the partner by the partnership

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Example

• David is a partner in Partnership A during 2018

• The partnership reports a loss of $100,000 on its partnership return

• On the 2018 Schedule K‐1 attached to the partnership return, the partnership reports $5,000 as David's distributive share of that loss

• On the 2018 Schedule K‐1 furnished to David, however, Partnership reports $15,000 as his distributive share of the loss

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Example – Cont’d

• David reports the $15,000 loss on his 2018 income tax return

• He has not satisfied the requirements of consistency because David reported his distributive share of the loss in a manner that is inconsistent with how his distributive share of the loss was reported on the 2018 partnership return filed

• If David does not receive a copy of the partnership return where they reported the $5,000 and only receives the K‐1 for $15,000 how does he meet the consistency requirement?

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Example – Cont’d

• § 6222(c)(2) provides that the partner is treated as having notified the IRS of an inconsistency, if the partner demonstrates that the treatment of the item on the return is consistent with the treatment of the item on the statement furnished to that partner by the partnership, and the partner elects to have this provision apply

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Terms and Definitions

• The “items of income, gain, loss, deduction, or credit” means all items and information required to be shown, or reflected, on a return of the partnership and the forms and instructions, for the partnership’s taxable year, and any information in the partnership’s books and records for the taxable year. This includes:

• (1) The character, timing, source, and amount of the partnership’s income, gain, loss, deductions, and credits, including whether an item is deductible, tax‐exempt, or a tax‐preference item

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• (2) The character, timing, and source of the partnership’s activities, including whether the partnership’s activities are passive or active

• (3) Contributions to, and distributions from, the partnership, including the value, amount, and character of those contributions and distributions

• (4) The partnership’s basis in its assets, the character and type of the assets, and the value or revaluation of the assets; including any effect the character or value of the partnership’s assets has on the sale or exchange of an interest in the partnership

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• (5) The amount and character of partnership liabilities, including whether a liability is recourse or nonrecourse and any changes to those liabilities from the preceding tax year

• (6) The separate category, timing, and amount of the partnership’s creditable foreign tax expenditures

• (7) Any elections made by the partnership and the consequences or effects of those elections, including a § 754 election, any election referenced in § 703(b), a § 761 election, and an election under §§ 6221(b) or 6226(a)

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• (8) Items related to transactions between a partnership and any person including disguised sales, guaranteed payments, § 704(c) allocations, and transactions to which § 707 applies

• (9) Any item resulting from a partnership terminating including because of a transaction under Rev. Rul. 99‐6

• (10) Items and any effects from a technical termination and partner capital accounts, including the release of a partner from a deficit restoration obligation

• (11)The term “partnership” is any partnership required to file a return under § 6031(a) 73



• (12) The term “partnership adjustment” is any adjustment in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share

• (13) The term “return due date” as the due date for filing the partnership return for a taxable year, determined without regard to extensions

• (14) The term “reviewed year” is the partnership taxable year to which the adjustments relate (§301.6241‐1(a)). The term “reviewed year partner” is the person who held an interest in a partnership at any time during the reviewed year (§301.6241‐1(a)(9))

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• (15) The term “adjustment year” is the partnership taxable year:

• In which a decision of a court becomes final

• An Administrative Adjustment Request (AAR) is made, or

• When a Final Partnership Agreement (FPA) is mailed (or if the partnership waives its right to a FPA, the year the waiver is executed by the IRS) (§301.6241‐1(a)(1))

• The “adjustment year partner” is any person who held an interest in a partnership at any time during the adjustment year of the partnership (§301.6241‐1(a)(2))

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Additional Definitions: §301.6241‐1(a)

• (1) A “pass‐through partner” means a pass‐through entity that holds an interest in a partnership

• (2) A “pass‐through entity” is a partnership (including a foreign entity that is classified as a partnership, an S corporation, a trust, (other than a trust described below), and a decedent’s estate

• (3) A “pass‐through partner” does not include disregarded entities or a trust that is wholly owned by only one person, whether the grantor or another person, and the trust reports the owner’s information to payors under §1.671‐4(b)(2)(i)(A)

• In addition, a “pass‐through partner” does not include entities such as a registered investment company or an estate investment trust

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• (4) A “partnership‐partner” means a partnership that holds an interest in a partnership

• A partnership‐partner is a type of pass‐through partner

• (5) An “indirect partner” is any person who has an interest in the partnership through their interest in one or more pass‐through partners

• For example, a shareholder in an S corporation that is a partner in a partnership is an indirect partner of that partnership

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• (6) A “partnership adjustment” is any adjustment to the amount of any item of income, gain, loss, deduction, or credit or any partner’s distributive share

• (7) An “imputed underpayment” is any amount determined in the audit

• (8) A “tax attribute” is anything that can affect, with respect to a partnership or partner, the amount or timing of an item of income, gain, loss, deduction or credit or that can affect the amount of tax due in any taxable year

• Examples of tax attributes include, but are not limited to, basis and holding period, as well as the character of items of income, gain, loss, deduction, or credit and carryovers and carrybacks of such items.

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Other Rules

• Where a partnership ceases to exist before a partnership adjustment takes effect, the partnership adjustment will be considered by the former partners of the partnership

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2017 Draft of Form 1065

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Questions

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The Scoop – Upcoming Dates

• November 1

• December 13, 2017

• Held at 8:00 am and 12:00 pm Central time

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Up Coming Webinarshttp://www.calt.iastate.edu/calendar‐node‐field‐seminar‐date/month

• Farm Expenses October 24, 2017

• Farm Income October 26, 2017

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The Schedule is Finalized for the 44th Annual Federal Income Tax Schools

• November 2‐3, 2017 – Maquoketa, Iowa – Centerstone Inn and Suites

• November 6‐7, 2017 – Le Mars, Iowa – Le Mars Convention Center

• November 8‐9, 2017 – Atlantic, Iowa – Cass County Community Center

• November 9‐10, 2017 – Mason City, Iowa – North Iowa Area Community College

• November 16‐17, 2017 – Ottumwa, Iowa – Indian Hills Community College

• November 20‐21, 2017 – Waterloo, Iowa – Hawkeye Community College

• December 11‐12, 2017 – Ames, Iowa and Live Webinar – Quality Inn and Suites

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The CALT Staff

William EdwardsInterim Director for the Beginning Farmer CenterInterim Director for the Center for Agricultural Law and [email protected]‐294‐6161473 Heady518 Farm House LnAmes. Iowa 50011

Kristine A. Tidgren

Assistant Director

E‐mail: [email protected]

Phone: (515) 294‐6365

Fax: (515) 294‐0700


The CALT Staff

Kristy S. Maitre

Tax Specialist


Phone: (515) 296‐3810

Fax: (515) 294‐0700

Tiffany L. Kayser

Program Administrator


Phone: (515) 294‐5217

Fax: (515) 294‐0700

the New Partnership Audit Regime 2017 - CALT Audit Issues...The New Partnership Audit Regime October...

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Transcript of the New Partnership Audit Regime 2017 - CALT Audit Issues...The New Partnership Audit Regime October...