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CSTC Academy: Wednesday Webinar Series - Partnership Audit Procedures for Tax Counsel
Wednesday, September 01, 2021, 10:00 AM - 11:40 AM PST
Category: Wednesday Webinar Series


Partnership Audit Procedures for Tax Counsel
Wednesday, September 1, 2021
10:00 AM to 11:40 AM

Cost: Member: $40 / Non-Member: $70

Speaker: Michel Stein, Esq
1 Federal Law Hour, 1 California Hour
IRS: 18QC1-T-01537-21-O
CTEC: 1000-CE-4936

Session Description:
The IRS Large Business and International Division stated in its most recent Focus Guide that an increase in partnership audits is underway. Tax professionals must identify critical issues for partnerships subject to BBA audit rules and implement strategies for managing these audits and minimize potential tax liability and penalties. The BBA centralized partnership audit regime replaced the Tax Equity and Fiscal Responsibility Act audit procedures and the electing large partnership rules. Under the BBA centralized partnership audit regime, the IRS generally assesses and collects any tax understatement at the partnership level. Under the BBA audit rules, many partnerships are subject to an entity-level audit by default. A partnership is subject to BBA centralized partnership audit rules unless it is an eligible partnership and makes an annual election out of BBA on a timely filed Form 1065. An eligible partnership is one with 100 or fewer partners, all of whom are either individuals, C corporations, or foreign entities treated as a C corporation if it were domestic, S corporations, or estates of deceased partners. Listen as we present BBA audit procedures, recent IRS enforcement actions, and concrete suggestions on managing BBA audits, taxpayer rights, and other critical items.

Knowledge Level: General

Michel Stein, Esq

MICHEL R. STEIN is a principal at Hochman Salkin Toscher Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government's ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer's and their advisors around the world.

Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.