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Course Description

Starting with returns filed for the 2018 tax year, new rules apply to IRS examinations of partnership income tax returns.  We will review the new procedures, when they benefit taxpayers and when they do not, and planning in light of the rules.  You will learn:

  • Procedures if the partnerships cannot or do not elect out of the rules.
  • Electing out of the rules - how to qualify (and many surprisingly don't) and how to elect
  • The partnership representative's surprisingly broad authority and how a partnership agreement (including an operating agreement) might address that person's duties to the partnership (including LLC)
  • How to navigate the procedures to ensure fairness to all and try to reduce administrative burdens that the rules impose on taxpayers


Steven B. Gorin

Steve is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. Lawyers, accountants and business owners regularly look to Steve for fresh, highly knowledgeable insights into the best possible tax and estate planning approaches to their transactions.

Steve crafts estate plans for individuals, keeping in mind their financial security and desire to save income and estate tax. In his work for businesses, Steve helps owners plan for the eventual sale (to co-owners, employees, or third parties) or transfer (to family members), and provides a legal framework for an orderly transition while strategically saving income, transfer, and FICA taxes.

Drawing on his background as an accountant — and his still-current CPA license and Chartered Global Management Accountant credential — Steve structures businesses to achieve business objectives and save income or estate tax. He has helped fledgling businesses organize, thriving businesses restructure to save hundreds of thousands of dollars of income tax when planning a transition to the next ownership group, and mature multi-million or billion-dollar businesses plan tax-saving transfers to the next generation.

Over the course of his 30-year career, Steve has amassed a deep knowledge of nearly every aspect of tax strategy for privately held businesses and freely shares that knowledge with others in the field. His quarterly newsletter, Business Succession Solutions," is considered essential reading for hundreds of CPAs and attorneys, who describe it as "a fantastic contribution to the field." Steve also maintains a blog, Business Succession Solutions, intended to help business owners — and those who advise or support them — consider smart tax strategies.

Steve is a highly visible member of the ABA's Real Property, Trust & Estate Law Section and the American College of Trust & Estate Counsel, which regularly directs its members to Steve's quarterly newsletter. He has represented both groups in comments to the IRS, the U.S. Treasury, and tax lawmakers.

Course Specifics

Oct 20, 2018

Compliance Information

Qualifies for CA Fraud: No

Learning Objectives

Upon successful completion of this course, participants will be able to:

  • Identify the new partnership audit rules
  • List issues to consider when drafting partnership sale agreements or operating agreements
  • Identify how to use business entities to save tax on investments

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