Centralized Audit Regime Issues for Buyers and Sellers of Partnership Interests: Protecting Against Audit Risks
Structuring the Purchase or Sale of Partnership Interests Under New IRS Audit Rules
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide guidance to tax counsel and advisers on BBA audit regime issues faced by buyers and sellers of partnership interests. The panel will discuss key points of interest in negotiating and structuring purchases or sales of partnership interests in light of the new partnership audit regime for both sellers and buyers. The panel will also provide an in-depth analysis of methods in assessing potential BBA audit risks and protecting against pre-acquisition liability.
Outline
- Critical provisions of the new centralized audit regime
- Authority of partnership representatives and associated risks
- Negotiating and structuring the purchase or sale of partnership interests in light of the new audit regime
- Key considerations for buyers
- Key considerations for sellers
- Assessing BBA audit risks and critical due diligence initiatives for buyers and sellers
Benefits
The panel will review these and other key issues:
- What are the implications of the new partnership audit rules on structuring partnership mergers or acquisitions?
- What are the challenges and risks associated with the selection and authority of a partnership representative?
- What are the key considerations in the negotiation and structuring of a purchase or sale of partnerships under the new audit rules?
- What are the factors to consider in assessing BBA audit risks?
- What are the due diligence initiatives for buyers and sellers to limit potential tax liability?
Faculty
Teresa Abney
Counsel
Crowell & Moring
Ms. Abney practices in the areas of federal tax controversy and litigation. Before joining Crowell & Moring, she... | Read More
Ms. Abney practices in the areas of federal tax controversy and litigation. Before joining Crowell & Moring, she was a trial attorney at the U.S. Department of Justice, Tax Division. At DOJ, Ms. Abney represented the U.S. as lead counsel in a wide variety of civil litigation in federal district and bankruptcy courts throughout the country. In recognition of her work, Teresa was awarded the Tax Division’s Outstanding Attorney Award in 2015 and Special Commendation in 2016. She has litigated matters involving research and development credits, business expense deductions, excise taxes, nonshareholder capital contributions, and domestic production deductions. She has handled cases in every stage of litigation, including discovery, motions for summary judgment, settlement negotiations, and trial. Ms. Abney has taken depositions, prepared witnesses for depositions, drafted and argued motions to compel and for summary judgment, negotiated at settlement conferences before private mediators and magistrate judges, and served as first chair in a two-day evidentiary hearing.
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Jonathan Stein
Director
Goulston & Storrs
Mr. Stein advises public and private companies, investment funds and real estate investors on corporate,... | Read More
Mr. Stein advises public and private companies, investment funds and real estate investors on corporate, partnership and international tax matters. He is experienced in representing buyers and sellers in taxable and tax-free M&A transactions; investment fund sponsors and institutional investors in fund formation and structuring of portfolio investments; and real estate investors and developers in optimizing complex joint venture strategies.
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