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Tax Liability › Bipartisan Budget Act › Tax Returns

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

Morgan Lewis

IRS Releases Tax Return Amendment Relief for BBA Partnerships

Morgan Lewis on

The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more

Burr & Forman

Don’t Forget to Update Your Operating Agreement for Partnership Audit Rule Changes

Burr & Forman on

The Bipartisan Budget Act of 2015 enacted sweeping changes to the federal audit regime for entities taxed as partnerships. The new audit rules became effective for tax years beginning on or after January 1, 2018. For tax...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

Akin Gump Strauss Hauer & Feld LLP on

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

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