On June 24, 2021, Megan L. Brackney participates in a panel entitled “Tips for Handling Audits of Pass-Through Entities Under the Centralized Partnership Audit Regime” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-boarder activities and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships who elect out of the centralized audit regime, the IRS will have to audit, assess and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.
Mike Desmond, Gibson Dunn & Crutcher, LLP, Los Angeles, CA
Megan Brackney, Kostelanetz & Fink, LLP, New York, NY
Rochelle Hodes, Crowe, LLP, Washington, DC
Holly Paz, Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
Click here for more information and to register.