PLI's Tax Controversy 2025: Navigating the New Enforcement Landscape

PLI's Tax Controversy 2025: Navigating the New Enforcement Landscape

• PLI New York, 1177 Avenue of the Americas
• Monday, March 24, 2025 9:00 AM - 5:00 PM EST

Kate Kraus will present "Unique Tax Controversy Issues Relating to Partnerships" at PLI's Tax Controversy 2025: Navigating the New Enforcement Landscape on March 24, 2025.

On October 22, 2024, the IRS announced the launch of a pass-through compliance unit within the Large Business & International Division, with the goal of bringing together teams of specialists from across the agency to more efficiently conduct audits of pass-through entities. These audits will mainly be conducted under the Bipartisan Budget Act (“BBA”) procedures in effect for tax years beginning in 2018. This panel will focus on steps being taken by the IRS to coordinate partnership audits, discuss partnership-related campaigns and other areas of substantive focus and provide insight into procedural aspects of the BBA rules, including the determination of imputed underpayments, when the modification rules may be useful, how the modification procedures are being implemented, and pitfalls to watch out for with push-out elections.

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