09 December 2019 IRS releases final forms related to BBA partnership administrative adjustment requests and push-out elections On December 6, the IRS released two new final forms (attached) for partnerships under the centralized partnership audit regime enacted by the 2015 Bipartisan Budget Act (BBA): The new forms are required for push-out elections under IRC Section 6226 and administrative adjustments requests (AARs) under IRC Section 6227. The IRS released draft versions of the forms in September 2019. The final versions are consistent with the draft forms. For additional background and discussion of the draft forms, see Tax Alert 2019-1747. Final instructions on the forms are not yet available. However, the IRS published draft Instructions in November 2019: Some partnerships, particularly those looking to file BBA AARs this calendar year, have been anxiously awaiting the release of the final Forms 8985 and 8986. Until the IRS releases the final Instructions, filers should rely on the draft instructions in completing and filing Forms 8985 and 8986. In addition, filers should note that, per the draft instructions and until further notice, audited partnership and pass-through partners must submit Forms 8985 and 8986 to the IRS by fax at the number provided in the draft instructions.
Document ID: 2019-2166 | |||||||||||||||
