Education & Public Speaking

Partnership Tax Education Grounded in IRS Experience

Partnership taxation is one of the most complex areas of federal tax law. Effective professional education requires more than explaining statutory and regulatory provisions. It requires helping practitioners and students understand how the rules operate in practice and how they interact with federal tax administration.

Mark A. Silva, EA, founder of Partnership Tax Advisors LLC, is available for educational programs and speaking engagements involving partnership taxation, IRS procedures, and related federal tax matters.

Drawing upon his experience as a former IRS Revenue Agent, Technical Advisor to IRS Revenue Agents, and IRS Headquarters Senior Policy Analyst, Mark brings a perspective to tax education developed from applying the tax law, providing technical guidance to IRS personnel, and participating in the development of IRS policy and compliance initiatives.

Partnership Taxation

Partnership taxation presents practitioners with technical issues that can become difficult quickly, particularly when Subchapter K concepts, partnership agreements, allocations, transactions, and reporting requirements interact.

Educational programs can be developed around subjects involving partnership taxation and the practical application of partnership tax rules.

Potential subject areas may include:

  • Partnership formations and contributions

  • Partnership allocations

  • General Rules of Distribution

  • Sales and exchanges of partnership interests

  • Partnership liabilities

  • Loss Limitations

  • Section 743(b) and Section 734(b) basis adjustments

  • Payments to Retiring Partners

  • Schedule K-1 reporting issues

  • Partnership transactions and related reporting considerations

  • IRS partnership examination and compliance considerations

The particular subject matter and level of technical detail can be tailored to the needs and experience of the audience.

Understanding the IRS Perspective

Technical tax rules do not operate in isolation from tax administration.

Understanding how the IRS approaches an issue can provide useful context when practitioners are evaluating a tax position, responding to an IRS inquiry, or advising a client.

Mark's experience within the IRS provides a perspective that can be incorporated into educational programs involving subjects such as:

  • IRS examination considerations

  • Federal tax administration

  • IRS procedures and processes

  • Taxpayer and practitioner interactions with the IRS

  • Evaluating IRS notices and proposed adjustments

  • Documentation and substantiation

  • Selected IRS collection and resolution issues

  • The relationship between technical tax issues and IRS administration

The objective is not simply to describe an IRS process, but to help practitioners and students understand the tax issue underlying the process and the considerations that may affect its resolution.

Programs for Tax Professionals and Professional Organizations

Educational presentations can be developed for organizations seeking substantive federal tax programming.

Possible audiences include:

  • CPA societies and associations

  • Enrolled agent organizations

  • Bar associations and attorney groups

  • Tax practitioner organizations

  • Accounting and tax firms

  • Professional education providers

  • Educational institutions

  • Conferences and seminars

  • Other organizations serving tax professionals

Programs may be appropriate for in-person presentations, conferences, seminars, webinars, or other professional education formats.

A Practical Approach to Technical Tax Education

Complexity does not have to mean unnecessary complication.

The goal of a Partnership Tax Advisors LLC educational program is to take a technically demanding subject and organize it so practitioners and students can understand both the governing tax principles and their practical significance.

Depending upon the subject, a presentation may incorporate:

  • Explanation of the applicable tax rules

  • Practical examples

  • Identification of common problem areas

  • Discussion of reporting considerations

  • Analysis of IRS administrative considerations

  • Interaction among related partnership tax provisions

  • Practical considerations for tax practitioners

Programs can be tailored to the technical experience of the audience and the particular subject matter being addressed.

Customized Programs

Professional organizations and educational institutions do not always need an off-the-shelf tax presentation.

A program can be developed around a particular partnership tax or federal tax subject that is important to an organization's members, practitioners, students, or participants.

Depending upon the engagement, the subject matter, length, format, and technical level can be discussed with the sponsoring organization so that the program is appropriate for the intended audience.

IRS Experience Matters

Mark A. Silva, EA, brings a distinctive perspective to professional tax education from his experience as an IRS Revenue Agent, Technical Advisor to IRS Revenue Agents, and IRS Headquarters Senior Policy Analyst.

As a Revenue Agent, Mark worked directly with taxpayers and tax practitioners in the examination process. Later, as a Technical Advisor to IRS Revenue Agents, he provided technical guidance to agents dealing with complex tax issues.

At IRS Headquarters, Mark's responsibilities as a Senior Policy Analyst broadened that experience from individual examinations and technical issues to the administration of the tax system itself. His work included creating or providing direct input into tax form changes, legislative changes, tax return modeling, and compliance initiatives. He also provided the expertise used to build the flow-through compliance infrastructure within the IRS Small Business/Self-Employed Division.

Taken together, that work provided experience with important elements affecting how the IRS identifies returns for examination, conducts examinations, develops compliance initiatives, and balances enforcement with taxpayer service.

That combination of experience provides a perspective particularly relevant to tax professionals and students. Mark's educational approach draws upon experience at the examination, technical, and IRS Headquarters policy levels to help participants understand not only the tax law, but also how that law operates within the federal tax administration system.

Interested in an Educational Program or Speaking Engagement?

If your organization or educational institution is planning a tax conference, professional education program, webinar, seminar, classroom program, or other event and is interested in a presentation involving partnership taxation, IRS procedures, or related federal tax issues, Partnership Tax Advisors LLC welcomes the opportunity to discuss the program.

Contact Partnership Tax Advisors LLC to discuss your organization, audience, proposed subject matter, and educational objectives.