Web Page Providing IRS Guidance for BBA Centralized Partnership Audit Regime Published by the Agency
The IRS has established a web page on the agency’s site devoted to the BBA Centralized Partnership Audit Regime.[1]
The page is meant to provide a centralized location for the agency’s information and guidance on the new audit regime introduced by the Bipartisan Budget Act of 2015, which replaces the prior TEFRA partnership audit regime.
The sections of guidance found on the page are:
Filing Requirements;
BBA Partnership Audit notices;
Regulations for the BBA audits; and
Interim Guidance for the BBA audits.
The page concludes with a high level comparison table:
| Partnership Procedures | TEFRA | BBA |
|---|---|---|
| Partnership point of contact for examination | Tax Matters Partner | Partnership Representative |
| Partner participation rights during examination | Partners have the ability to participate in the examination and challenge partnership adjustments | Partners have no participation right to challenge partnership adjustment |
| Partner consistency of reporting | Partners must report items consistently with the partnership | Partners must report items consistently with the partnership |
| Notice requirements | Notice requirements (NBAP, FPAA) | Notice requirements (NAP, NOPPA, FPA) |
| Items adjusted during examination | Partnership item/Affected item | Partnership related item (PRI) |
| Where adjustments/assessments occur | Adjustments at the partnership level/tax assessment at the partner level | Adjustment and assessment at the partnership level (imputed underpayment) |
| Distinct phases of examination | Field examination | Field examination phase |
| Not applicable | Modification phase (optional) | |
| FPAA phase | FPA phase | |
| Not applicable | Push-out phase (optional) |
[1] “BBA Centralized Partnership Audit Regime,” IRS website, September 1, 2020 https://www.irs.gov/businesses/partnerships/bba-centralized-partnership-audit-regime (retrieved September 2, 2020)