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The IRS has announced its launch of a website to help partnerships navigate the rules and procedures applicable to partnerships under the centralized partnership audit regime of the Bipartisan Budget Act of 2015 (BBA).

The website, intended to serve as a unified source of BBA information for partnerships, includes high-level information on the BBA regime, as well as more detailed information on certain filing requirements, descriptions of what to expect during an audit and links to recent IRS regulations and other guidance.

With respect to filing requirements, the website describes procedures and requirements related to (1) designating a partnership representative, (2) opting to elect out of the centralized partnership audit regime, and (3) filing an administrative adjustment request (AAR) to change a prior return.

The website's guidance on BBA audits follows and builds on the "BBA Roadmap for Taxpayers" released by the IRS in July (see Tax Alert 2020-1772). In addition to the BBA Roadmap, the website includes more detailed descriptions of the various notices that the IRS issues in the course of a BBA audit.

For more in-depth technical guidance, the website includes links to various final and proposed regulations, notices and interim guidance issued by the IRS on the BBA regime over the last couple years.

The IRS encourages taxpayers to return to the website often for BBA information and adds that it will post electronic submission instructions for BBA-related forms to the website once available.

Implications

The IRS Large Business and International Division (LB&I) signaled in its most recent Focus Guide that an increase in partnership audits was on its way. The release of this new website, along with recent statements by LB&I executives, confirms this emerging trend.

In June, LB&I Commissioner Douglas O'Donnell noted that, following the expiration of the "People First Initiative" on July 15 (see discussion in Tax Alert 2020-0722), the IRS expected to start examinations of several hundred high net-worth individuals, many of which would include inquiries into partnerships related to the taxpayer. Then, in August, LB&I Deputy Commissioner Nicole Flax said that LB&I is looking to roll out a Large Partnership equivalent of the Division's Large Corporate Compliance program that would likely be launched next year.

Given the IRS's increased focus on examining partnerships, taxpayers and their representatives may want to bookmark the new website now for future reference.

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