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Partnerships Bipartisan Budget Act TEFRA

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

Holland & Knight LLP on

The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Morrison & Foerster LLP

The Impending Large Partnership Audits

In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more

Maynard Nexsen

Is Your Partnership Ready for the IRS's New Centralized Audit Regime?

Maynard Nexsen on

The new centralized audit regime for partnerships established by the Bipartisan Budget Act of 2015 (“BBA”) has been in effect since January 1, 2018, but is your partnership or LLC treated as a partnership for tax purposes...more

Bracewell LLP

Application of Partnership Audit Rules to Private Funds

Bracewell LLP on

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more

Farrell Fritz, P.C.

The New Partnership Audit & Collection Regime: Its Time Has Come

Farrell Fritz, P.C. on

Beginning 2018, the IRS is authorized to collect from a partnership any tax deficiencies arising out of the partnership’s operations for a taxable year, even if the persons who were partners in the year to which the...more

Dentons

A Summary of the Proposed Partnership Audit Regulations

Dentons on

This blog post is intended to identify the most material aspects of the proposed regulations the IRS has introduced to implement the BBA partnership audit rules, and provide guidance on what actions a partnership should...more

Cole Schotz

Partnerships Prepare For New Audit Regime

Cole Schotz on

On November 2, 2015, new partnership audit rules, repealing existing TEFRA rules, were enacted in Section 1101 of the Bipartisan Budget Act (“BBA”). On August 15, 2016, Treasury published temporary regulations (TD 9780, 81...more

Fox Rothschild LLP

IRS Issues Guidance To Examiners Handling BBA Partnership Audits

Fox Rothschild LLP on

As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships are subject to a...more

Blank Rome LLP

Significant Changes to Partnership Tax Audits Coming in 2018

Blank Rome LLP on

In less than six months, on January 1, 2018, the new centralized partnership audit rules enacted by Congress as part of the Bipartisan Budget Act of 2015 (“BBA”) will go into effect. The new rules were drafted in response to...more

Dechert LLP

Reissuance of Proposed Regulations on Partnership Audit Rules

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

Morrison & Foerster LLP

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Butler Snow LLP

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

Butler Snow LLP on

The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Proposed Regulations on Centralized Partnership Audit Regime

On January 18, 2017, the IRS released proposed regulations (the "Proposed Regulations") to implement Section 1101 of the Bipartisan Budget Act of 2015 (BBA),1 which replaces the current rules governing partnership...more

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