TAX2516. Hot Topics under the BBA Partnership Audit Regime

The centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (the "BBA"), generally effective for partnership taxable years beginning on or after January 1, 2018, has changed the way partnerships and their partners are affected by changes to partnership returns. These changes can be made by the partnership under the administrative adjustment request (AAR) procedures or by the IRS in an IRS partnership audit. In recent years, partnerships have been a primary focus of the IRS' enforcement activities. The BBA rules are complex, and continue to challenge taxpayers, their advisers, and the IRS. This presentation will focus on the current state of the BBA partnership audit regime and provide tips for navigating these rules.

Learning Objectives:

• Describe the current IRS partnership enforcement landscape, and how it has evolved since BBA was enacted.
• Explain challenges with the AAR process and IRS audits and ways to navigate these challenges.
• Explain what the future of the BBA partnership audit looks like, and which changes could simplify the regime.