Congress recently passed the most significant changes in partnership tax in more than 30 years, disrupting businesses from oil and gas to private equity to family limited partnerships. The new partnership audit rules apply to partnership tax years beginning after December 31, 2017, but all partnerships (big and small) should take action now to begin to implement changes required under the new law. This course will briefly explain the fundamentals of the current Tax Equity and Fiscal Responsibility Act (TEFRA) partnership audit rules with a focus on the difficulties with the process that led to the replacement of TEFRA in the Bipartisan Budget Act of 2015. The course will then describe the new partnership audit regime, discuss how it will affect partnerships in every industry, and then detail the steps you should take now to prepare for 2018.
Latham & Watkins LLP
Counsel
[email protected]
(202) 637-3376
Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm.