New IRS Partnership Audit Rules: Where Things Stand in 2021

Latham lawyers Joshua Wu and Jason Grover will discuss the new centralized partnership audit regime and key issues that practitioners should consider.


Congress dramatically changed the IRS partnership audit rules for tax years beginning after December 31, 2017. Treasury and the IRS continue to release guidance with respect to the new centralized partnership audit regime, but some questions remain unanswered. The new regime is also becoming a significant issue in numerous IRS examinations and appeals. The presenters will discuss the new centralized partnership audit regime and 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 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


Joshua Wu, Counsel, Latham & Watkins LLP

Jason Grover, Associate, Latham & Watkins LLP


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