04 August 2016 US Treasury and IRS release guidance on electing into the new BBA partnership audit regime The US Treasury and Internal Revenue Service have released temporary and proposed regulations (T.D. 9780 and REG-105005-16) to provide guidance on electing to apply the new partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA). The regulations provide the time, form and manner for making this election for returns filed for partnership tax years beginning after November 2, 2015 and before January 1, 2018. Without this necessary guidance, a partnership would not be able to make a valid election to apply the BBA regime to partnership tax years beginning before January 1, 2018. This is the first set of BBA audit regulations issued and will be followed in the future by a series of additional guidance before January 1, 2018. A Tax Alert is forthcoming. Document ID: 2016-9006 |