Which Form 8865 Audit 2024

Morning, everyone. We will just jump right into the slides, although I do want to spend 30 seconds on the first slide, which normally I wouldn't do. I just want to point out that the title of this talk is about every partnership in LLC operating agreement needing to be amended. When my managing partner, who is also a tax guy, first mentioned these rules, he made a statement along the lines of we're going to have to amend all our agreements. I thought, well, that sounds typical, you know, overreaction to legislative changes. The more I started reading these rules and thinking about the implications, the more I became convinced that these rules really are going to require every LLC, every partnership to amend their agreement in some way. We are going to talk about some of those amendments, and certainly, every LLC or partnership won't have to make all of these changes. But I think these will have to be taken into account in some way by every partnership in every LLC. So, let's move on to the next slide. We already talked about me, okay? So, these new audit rules came into effect in November of last year. These are law, not temporary regs or proposed or anything like this. These are code sections in the Internal Revenue Code. They are not mandatory until 2018, and that presents a problem for us lawyers and accountants. It's hard to get people focused on a change that doesn't happen until 2018, especially when these were passed in 2015. I'm still having a hard time getting people to really start thinking about this. These changes will require a lot of thought and discussion among partners and members in LLCs. I certainly don't think that at least beginning next year, it's too early...