Administrative Adjustment Requests (AARs): Typical Scenarios, Push-Out and Pull-In Elections, Completing Related Forms

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Wednesday, July 19, 2023
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This webinar will walk tax practitioners through the reporting responsibilities for administrative adjustment requests (AARs) and explain when an AAR is required or should be considered. Our panel of partnership and procedure professionals will address the initial determination whether an AAR is required, considerations relevant to that determination, and the common forms that could be required using actual examples of typical situations. The panel will also address the effect an AAR, once filed, has on the partnership’s partners.
Faculty

Mr Armstrong is a Director at KPMG Washington National Tax - Practice, Procedure, & Administration.

Mr. Chan is a managing director of the Passthroughs Group of KPMG’s Washington National Tax (WNT) Practice with more than 15 years of business experience. He works with partnership clients across a variety of industries, modeling the tax consequences of partnership transactions, developing complex allocation templates, and writing memorandums and opinions on partnership technical issues.
Description
Amending partnership returns has always been complicated. Under the Bipartisan Budget Act of 2015 (BBA) guidelines, the complexities of correcting prior partnership returns have increased substantially. A tax professional must understand when an amended return can be filed as opposed to an AAR, which additional forms are required to be filed, and the impact of filing an AAR on the partnership and its partners.
For years Prior to BBA, and for partnerships eligible to elect out of the BBA, partnerships and LLCs can file a 1065-X to amend the prior year return. For partnership taxable years subject to the BBA, Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request, along with an amended Form 1065, is used to revise prior returns. Alternatively, and adding to the complexity of these rules, Form 1065-X may be used to file an AAR under certain circumstances. In addition, the partnership could be required to file and issue to its partners a Form 8986, Partner's Share of Adjustment(s) to Partnership-Related Item(s) (Required Under Sections 6226 and 6227) if it decides (or is required to) to push-out the AAR adjustments to its partners.
Filing an AAR resets the statute of limitation for the IRS to make additional partnership adjustments. Whether the adjustments requested on the AAR results in an “imputed underpayment” for the partnership also must be considered. Tax professionals working with partnerships and LLCs must thoroughly grasp the new reporting responsibilities for partnership adjustments and understand the impact of filing an AAR has on both the partnership and its partners.
Listen as our panel of partnership procedural experts systematically works through correcting prior partnership returns under current guidelines by providing examples of AARs, including preparing each required form and addressing the potential effects on partners' returns.
Outline
- Amending partnership returns
- Amended Returns
- Superseding returns and other alternatives
- AARs
- Preparing Form 1065-X or Form 8082 – Notice of Inconsistent Treatment or AAR
- Reporting push-out adjustments
- Typical scenarios and examples
- Effects on partners of receiving Form 8986
Benefits
The panel will review these and other critical issues:
- When should a partnership consider making a push-out election?
- Which partnerships can file a 1065-X?
- Properly completing an AAR utilizing Form 8082 or Form 1065-X
- Examples of completing an AAR
- Key considerations before filing an AAR
- Effects on partners
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify partnerships eligible to file Form 1065-X
- Determine forms that may need to be filed in order to file an AAR
- Determine in which year AAR adjustments are reported by partners
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and their respective partners and shareholders.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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