The Bipartisan Budget Act of 2015 eliminated the TEFRA partnership tax audit rules and created new partnership tax audit rules that tax effect January 1, 2017. The following articles deal with these new partnership audit rules.
Text of Bipartisan Budget Act of 2015 (BBA) Partnership Audit Provisions: Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules for partnerships subject to the new regime, including procedures for electing out of the centralized partnership audit regime, filing administrative adjustment requests, and the determination of amounts owed by the partnership or its partners attributable to adjustments that arise out of an examination of a partnership.
- Proposed IRS Regulations Under Section 1101 of the BBA: This document contains proposed regulations regarding implementation of section1101 of the Bipartisan Budget Act of 2015. The proposed regulations also address the scope of the centralized partnership audit regime and provide definitions and special rules that govern its application, including the designation of a partnership representative. The proposed regulations affect partnerships for taxable years beginning after December 31, 2017 and