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New IRS Partnership Audit Rules: Where Things Stand in 2021

NEW IRS PARTNERSHIP AUDIT RULES: WHERE THINGS STAND IN 2021

Cost Free
Presentation Length 1.0 hour

Recorded DateMay 24, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Congress dramatically changed the IRS partnership audit rules for tax years beginning after December 31, 2017. The Treasury and the IRS continue to release guidance regarding the new centralized partnership audit regime, but some questions remain unanswered. The new administration is also becoming a significant issue in numerous IRS examinations and appeals. The presenters will discuss the new centralized partnership audit regime as well as the issues that practitioners should consider before a partnership is audited and once a partnership return comes under IRS examination.

Learning Objectives:


  • Define and gain a high-level understanding of the new centralized partnership audit regime and how to identify when it may be an issue for you or your clients

  • Summarize the current guidance from the IRS/Treasury and identify areas where there are no clear answers

  • Give examples of defending a partnership audit and how to deal with penalties asserted in such audits

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Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
 
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
 
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm. 

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Jason Grover is an associate in Latham & Watkins' Tax Controversy Practice and a Washington, D.C. office member. Mr. Grover represents taxpayers in all stages of federal tax controversies, including exam, appeals, and litigation in the US Tax Court, the US Court of Federal Claims, and the US district courts. Mr. Grover has led audits resulting in no change letters, made appeals arguments resulting in complete government concessions, and third-chaired litigation resulting in no-adjustment decisions. Mr. Grover has particular knowledge of partnership audits’ procedural and substantive aspects—both under the legacy TEFRA regime and under the new and evolving BBA rules—and has spoken and published on the subject. Mr. Grover's experience in this area allows him to help clients navigate this complex and changing landscape and avoid expensive disputes with the IRS and among partnership members.
 
Mr. Grover has experience across various industries and has represented clients in medical devices, software, oil and gas, financial institution, natural resources, and non-profit spaces. Mr. Grover's litigation experience encompasses complex corporate and individual tax matters involving economic substance, debt-equity, passive activity, partnership allocation, employment tax, and penalty issues. Mr. Grover also has substantial experience in the development and litigation of transfer pricing cases. 
 

About Our Presenter

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Latham & Watkins is a global law firm with more than 3,000 lawyers in its offices located in Asia, Europe, the Middle East, and the United States. The firm has internationally recognized practices in a wide spectrum of transactional, litigation, corporate and regulatory areas. Our success is grounded in our devotion to the collaborative process, which reaches across global offices and practices and draws upon our deep subject matter expertise, an abiding commitment to teamwork and a powerful tradition of creative lawyering.