PS: BBA Partnership Audits and Administrative Adjustment Requests

General Description:

The Bipartisan Budget Act (BBA) changed how partnerships make adjustments to previously filed returns. Rather than filing an amended return, the BBA requires certain partnerships to either pay the tax on the increase in the partnership taxable income or make a push-out election. This seminar will cover the tax effect, such as when a tax partnership is responsible for the additional tax; when the push-out election is required; and the potential problems that might be encountered by a partner when the push-out election is either required or the partnership opts to push out the adjustment.

Learning Objective:

After completing this course the participant will be able to:

• Determine who is subject to the BBA audit rules. Is it all partnerships or just certain partnerships that are subject to the BBA audit rules?
• Determine what forms are required to be filed when a partnership subject to the BBA needs to make an adjustment to a previously filed return, including Forms 8978, 8980, 8982, 8983, 8985, and 8986.
• Determine whether a partnership will file a Form 8082 or a Form 1065-X to make an adjustment on a previously filed return, who is responsible for filing the form, and the time limits for filing the form.
• Explain the difference as to when a push-out election is required to be filed and when the partnership might elect to make the push-out election.
• Determine the effect of the statute of limitations for both the partnership and partners if a push-out election is made.
• Define a Superseding Tax Return and describe the effect of filing a Superseding Tax Return.
• Determine the tax effect to the partner if a push-out election is made or required and how much of the adjustment may be used in the event that the adjustment reduces taxable income for either one year or more than one year
• Summarize the effect on a tiered partnership if the push-out election is made.

Instructors:

Mark A. Vogel is a retired professor and director of the University of Denver Graduate Tax Program, where for 38 years he taught courses in individual, fiduciary, tax accounting, partnership, and corporate taxation. He is the author of Divorce Taxation Guide (John Wiley & Sons) and Individual Taxation (Shepards/McGraw-Hill). He received a J.D. and LL.M. in Taxation from the University of Denver College of Law and an undergraduate accounting degree from the University of Notre Dame. He is also a CPA licensed in Illinois.

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