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Eligible Partnerships Partnerships with 100 or fewer partners for the taxable year can elect out of the centralized partnership audit regime if all partners are eligible partners.
The BBA applies to all partnerships unless the partnership makes a valid election out of the BBA for a partnership tax year. Partnerships subject to the BBA are referred to as BBA partnerships, while partnerships that validly elect out of the BBA are referred to as non-BBA (or BBA elect out) partnerships.
Partnership procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA)
The IRS notifies the partnership at each stage of a Bipartisan Budget Act (BBA) audit, also called an examination. The partnership, partnership representative, or both will receive notices by mail.
15902: 1065 - Centralized Partnership Audit Regime It allows the IRS to assess and collect tax at the partnership level for eligible partnerships instead of the tax being assessed at the partner level.
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BBA Rules means the partnership tax audit rules enacted under the Bipartisan Budget Act of 2015 and all effective Regulations and other guidance issued thereunder or with respect thereto.
The Notice of Administrative Proceeding (NAP) is a statutory notification required by Internal Revenue Code section 6231. The NAP informs the partnership and partnership representative that the IRS has started an administrative proceeding.
The IRS notifies the partnership at each stage of a Bipartisan Budget Act (BBA) audit, also called an examination. The partnership, partnership representative, or both will receive notices by mail.
Partnerships with 100 or fewer partners for the taxable year can elect out of the centralized partnership audit regime if all partners are eligible partners. Eligible partners are: Individuals. C corporations.
In 1982, Congress enacted the Tax Equity and Fiscal Responsibility Act (TEFRA) partnership audit procedures to establish a unified process for determining tax attributable to partnership items. Under TEFRA, adjustments to partnership items were determined in a single proceeding conducted at the partnership level.

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