IRS launches BBA centralized partnership audit regime webpage
BBA centralized partnership audit regime webpage
The IRS today announced the launch of a “Bipartisan Budget Act” (BBA) centralized partnership audit regime webpage.
According to the IRS release—IR-2020-199—the new BBA centralized partnership audit regime webpage is intended to be a “one-stop location for anything BBA-related.” The webpage includes regulations and other guidance and instructions:
- For partnership representatives
- How to elect out of the centralized audit regime
- About administrative adjustment requests (AARs)
- What to expect during a BBA administrative proceeding
Read more on the centralized partnership audit regime webpage.
The BBA centralized partnership audit regime replaced the Tax Equity and Fiscal Responsibility Act (TEFRA) audit procedures and the electing large partnership rules. Under the BBA centralized partnership audit regime, the IRS generally assesses and collects any understatement of tax (imputed underpayment) at the partnership level.
A partnership is subject to BBA centralized partnership audit regime unless it (1) is an eligible partnership and (2) makes an annual election out of the centralized partnership audit regime on a timely filed Form 1065. An eligible partnership is one with 100 or fewer partners, all of whom are either individuals, C corporations, foreign entities that would be treated as a C corporation if domestic, S corporations or estates of deceased partners.
© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.