Overview
The centralized partnership audit regime under the Bipartisan Budget Act of 2015 (BBA) became effective for partnerships with tax years beginning after Dec. 31, 2017. BBA significantly impacts how the IRS audits partnership returns and collects any resulting taxes. Most significantly, an imputed underpayment of taxes is, under the default BBA provisions, a liability of the partnership itself rather than the relevant partners.
Under the regime, audit decisions on behalf of the partnership are made by a key individual,