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    • Home
    • Services
    • International Taxation
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    • Professional businesses
    • Contact Us
  • Home
  • Services
  • International Taxation
  • Partnership Taxation
  • Rental-Like Kind Exchange
  • IRS Tax Audit
  • IRS Debt Collectors
  • Professional businesses
  • Contact Us

Partnerships and Bipartisan Budget Act (BBA)

 The Bipartisan Budget Act of 2015 (BBA) fundamentally reshaped how the IRS audits partnerships, replacing the old TEFRA rules with a centralized partnership audit regime effective for tax years beginning in 2018.  CPA tax advising, representation and preparation of amended tax returns.

Find out more

Luis Ramirez CPA. Partnership Procedures

Centralized Audit and Collection

The IRS now assesses and collects any tax underpayment (called an Imputed Underpayment or IU) directly at the partnership level, not from individual partners. Partnerships may modify the IU or elect to push out adjustments to partners via statements on their individual returns.

Partnership Representative

  •  Replaces the old “tax matters partner” concept.
  • Must be designated annually on Form 1065.
  • Can be any person or entity with a substantial U.S. presence—does not need to be a partner.
  • Holds sole authority to act on behalf of the partnership in IRS proceedings, including settlement and litigation decisions

Election Out of the regime

  •  Available only to partnerships with 100 or fewer eligible partners (individuals, C corps, S corps, estates).
  • Must be made annually on a timely filed Form 1065.
  • Partnerships with other entities (e.g., trusts, partnerships) as partners cannot elect out.

Administrative Adjustment Requests

  • Replaces amended returns for partnerships.
  • Filed using Form 1065X.
  • Adjustments are generally taken into account in the year the AAR is filed, not retroactively.

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