Reconciling State and Federal Audits After New IRS Partnership Audit Regulations: Tax Reporting Challenges
MTC Model Partnership Audit Reporting Statute; State Tax Audit, Assessment and Collection Procedures
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax professionals with an up-to-date look at the impact of the new IRS partnership audit rules on state tax regulations, audits, assessments and collection procedures. The panel will discuss recently released IRS final regulations, an overview of the new partnership audit processes in detail, and challenges associated with state reporting obligations resulting from federal audits.
Outline
- IRS final partnership audit regulations
- Constitutional limitations
- Nexus
- Nonresident and out-of-state partnerships
- Discrimination
- Fair apportionment
- MTC model partnership audit reporting statute and recent state regulations
- Challenges with push-out election, tiered structures and new QBI deduction
- Key planning techniques and best practices for tax professionals
Benefits
The panel will review these and other critical issues concerning the impact of the new IRS partnership audit rules on state tax administration:
- Critical components of the IRS final partnership audit regulations
- Understanding constitutional limitations such as nexus, residency, discrimination and fair apportionment
- The MTC model partnership audit reporting statute
- Recently enacted and pending state regulations addressing state tax audit, procedures and collections
- Issues with the push-out election, tiered structures and the new QBI deduction in state tax administration
- Best practices for tax professionals in handling state tax reporting of federal audits and reassessments
Faculty
Nikki E. Dobay
Senior Tax Counsel
Council On State Taxation
Ms. Dobay is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of... | Read More
Ms. Dobay is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of multi-jurisdictional entities. Prior to joining COST, she was Manager at PwC, where she focused on state and local tax matters.
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Mark G. Kmiecik
Shareholder
Davis & Kuelthau
Mr. Kmiecik is a corporate attorney and advises clients on international, federal, state, and local tax matters,... | Read More
Mr. Kmiecik is a corporate attorney and advises clients on international, federal, state, and local tax matters, as well as represents clients in the areas of estate planning, probate and trust administration, business succession planning, marital property, and tax planning. His practice includes planning for unique assets, international considerations, and beneficiaries with special needs. He authored the article, New Partnership Audit Rules for 2018.
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Fredrick J. Nicely
Senior Tax Counsel
Council On State Taxation
Mr. Nicely is Senior Tax Counsel for the Council On State Taxation (“COST”). Before joining COST, Mr.... | Read More
Mr. Nicely is Senior Tax Counsel for the Council On State Taxation (“COST”). Before joining COST, Mr. Nicely served in the Ohio Department of Taxation for four years as Deputy Tax Commissioner over Legal and for the prior seven years as the Department’s Chief Counsel. His responsibilities at the Department included testifying before legislative committees, participating as an alternative delegate for Ohio at Streamlined Sales Tax Project meetings, and reviewing legal documents issued by the Department, including deciding the merits of filing an appeal. Mr. Nicely is a frequent speaker and author on Ohio’s tax system and on multistate tax issues generally. He also has extensive experience in public utility tax law, having served as an administrator of the Department’s public utility tax division.
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