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BBA Partnership Audit Rules and Procedures

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A practice-focused federal tax course on the centralized partnership audit regime — election out, the Partnership Representative, imputed underpayment, push-out election, and Administrative Adjustment Requests.

This course is a practice-focused, four-module program on the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA), which replaced the TEFRA and electing-large-partnership audit rules for partnership tax years beginning after December 31, 2017. It goes beyond a general overview of the regime to build the practical skills a preparer needs at the desk: determining whether a partnership can and should elect out of the centralized regime, correctly designating and understanding the authority of a Partnership Representative, calculating an imputed underpayment and pursuing available modifications, deciding between paying the imputed underpayment at the partnership level or pushing the adjustments out to reviewed-year partners, and using an Administrative Adjustment Request to correct a previously filed return under the regime’s own rules rather than an ordinary amended return.

This course assumes general familiarity with individual and partnership federal income tax preparation. Course content is grounded in IRC §§6221 through 6241 as enacted by the Bipartisan Budget Act of 2015 (Public Law 114-74) and amended by the Protecting Americans from Tax Hikes Act; Schedule B-2 (Form 1065) and its instructions; Form 8979 (Partnership Representative designation); Form 8986 and Form 8985 and their instructions; and the current Instructions for Form 1065. Where a rule differs from the former TEFRA regime — particularly partner participation rights and the identity and authority of the partnership’s designated representative — the course states the distinction explicitly rather than assuming prior TEFRA familiarity carries over unchanged.

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