Appropriations bill changes partnership audit regime

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The $1.3 trillion omnibus appropriations bill passed by Congress last week includes some modifications to the Internal Revenue Service’s centralized audit regime for auditing large partnerships.

The centralized audit regime is supposed to make it easier for the IRS to audit large partnerships by being able to audit the entire partnership as a whole rather than every single partner. The new partnership audit regime was included as part of the Bipartisan Budget Act of 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level.

The technical corrections in the appropriations bill enable a partner’s adjustments…

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