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.


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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.

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