Partnership Tax Audit Rules

This practice note discusses the partnership audit rules enacted under the Bipartisan Budget Act of 2015 (114 Pub.L. No. 74) (BBA) as effective January 1, 2018. The practice note provides an overview of the partnership audit regime introduced under the BBA and highlights certain topics that tax practitioners should consider in representing partnerships and multimember limited liability companies (LLCs) that are taxable as partnerships. It also provides suggestions on tax provisions for partnership agreements and for other documents to take the new rules into account.