Partnership Representative

Legal Resources

• NBER Working Paper (October 2015)
• Bipartisan Budget Act of 2015 (November 15, 2015)
• PATH Act 2015 (December 15, 2015)
• IRS Notice 2016-23 (March 21, 2016)
• Joint Committee on Taxation Blue Book (March 14, 2016)
• NY State Bar Comments (May 25, 2016)
• ABA Tax Section Comments (June 6, 2016)
• Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations (August 4, 2016)
• Temporary Regulations Section 301.9100 – 22T (T.D. 9780) (August 5, 2016)
• AICPA Letter (October 7, 2016)
• Technical Explanation of The Tax Technical Corrections Act of 2016 (December 6, 2016)
• Proposed Regulations: Centralized Partnership Audit Regime (January 19, 2017)
• Treasury Department Memo for LB&I and SB/SE Examiners (June 29, 2017)
• Tax Section State Bar of Texas Letter to Treasury and IRS (August 1, 2017)
• Proposed Regulations: Centralized Partnership Audit Regime: International Tax Rules (November 30, 2017)
• Proposed Regulations: Centralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural Provisions (December 19, 2017)
• Election Out of the Centralized Partnership Audit Regime (January 2, 2018)
• State Bar of Texas Comments (March 19, 2018)
• Consolidated Appropriations Act, 2018 (March 23, 2018)
• Revenue Agent Guidance for Administrative Adjustment Requests (AAR) under the Bipartisan Budget Act of 2015 (BBA) Centralized Partnership Audit Regime (April 16, 2018)
• AICPA Comments (May 16, 2018)
• Revised Instructions for LB&I TEFRA Partnership Examinations (May 30, 2018)
• Final Regulations: Partnership Representative Under the Centralized Partnership Audit Regime and Election To Apply the Centralized Partnership Audit Regime (August 9, 2018)
• Proposed Regulations: Centralized Partnership Audit Regime (August 14, 2018)
• Form 8979 – Draft (August 14, 2018)
• Form 1065 – Draft (August 27, 2018)
• Draft Instructions for Electing Out of Centralized Partnership Audit Regime (IRC §6221) (October 3, 2018)
• AICPA Testimony on Centralized Partnership Audit Regime (October 9, 2018)
• Draft Instructions for Form 8979 (November 28, 2018)
• Tax Court Rules (December 19, 2018)
• Final Partnership Audit Regulations (December 21, 2018)
• Instructions for Form 1065, U.S. Return of Partnership Income (February 6, 2019)
• Agreement to Rescind Notice of Final Partnership Adjustment, Form 15057 (February 11, 2019)
• Form 8983 Certification of Partner Tax-Exempt Status for Modification Under IRC Section §6225(c)(3) (February 12, 2019)
• Form 8980 Partnership Request for Modification of Imputed Underpayments Under IRC Section 6225(c) (February 12, 2019)
• Letter from Drita Tonuzi, IRS Chief Counsel Office Recommends Tax Court Rule Changes (March 1, 2019)
• Form 8981, Waiver of the Period Under IRC Section 6231(b)(2)(A) and Expiration of the Period for Modification Submissions Under IRC Section 6225(c)(7) (March 2019)
• Form 8984, Extension of the Taxpayer Modification Submission Period Under Section 6225(c)(7) (March 14, 2019)
• Form 1066, U.S. Real Estate Mortgage Investment Conduit (REMIC) Income Tax Return (March 2019)
• IRS Appeals BBA Procedures (March 25, 2019)
• Form 13043 – Interim Guidance on Initial Taxpayer Contact in Partnership Examinations (July 3, 2019)
• The Tax Court finalized new rules for court cases under the centralized partnership audit regime and modified existing rules needed to implement the change in law. (July 15, 2019)
• Draft – Form 8978, Partner’s Audit Liability Under Section 6226 (August 6, 2019)
• Draft – Form 8978, Schedule A, Partner’s Audit Liability Under Section 6226 (August 6, 2019)
• IRS Appeals BBA Procedures (October 18, 2019)
• IRS Interim Guidance Memorandum (October 24, 2019)
• Draft – Form 8978, Partner’s Additional Reporting Year Tax (February 20, 2020)
• IRS Clarifications for Instructions for Form 8082 (March 18, 2020)
• IRS Memorandum for All LB&I and SB/SE Frontline Managers and Examiners (April 1, 2020)
• IRS Provides Limitations Periods for Making Partnership Adjustments (May 26, 2020)
• IRS Treatment of Enforcement Matters (November 20, 2020)
• Notice 2021-13 Relief for Partnerships from Certain Penalties Related to the Reporting of Partners’ Beginning Capital Account Balances (January 2021)
• Delegation Order 4-52 (January 21, 2021)
• Tax Section State Bar of Texas Letter to Treasury and IRS (January 25, 2021)
• IRS Appeals Memorandum – Reissuance of Bipartisan Budget Act (March 19 2021)
• IRS Teleconference Treatment of Special Enforcement Matters (March 25, 2021)
• IRS Memorandum Re Interim Guidance on Application of 26 U.S.C. §6103(e)(10) for TEFRA and BBA Partnerships (April 14, 2021)
• AICPA Letter- Changes to Simplify and Improve the AAR Process Under the Centralized Partnership Audit Regime and Proposed “AAR-EZ” Process Framework (May 25, 2021)
• GAO Letter to IRS Commissioner Re More Time Needed for Year-End Data Results for Partnership Audits (June 4, 2021)
• IRS Notice Transition Period Penalty Relief for New Schedules K-2 and K-3 for Forms 1065, 1120-S and 8865 (July 1, 2021)
• Senate Finance Committee Chair Ron Wyden Discussion Draft Legislation (September 10, 2021)
• ABA Section of Taxation Comments on BBA Special Enforcement Matters (October 8, 2021)
• IRS Email Advise Regard Whether Adjustments to Partnership-Related Items Are Included in Calculation of the Partnership’s Imputed Underpayment (November 24, 2021)
• TIGTA Report: Centralized Partnership Audit Regime Rules Have Been Implemented; However, Initial No-Change Rates Are High and Measurable Goals Have Not Been Established (March 17, 2022)

• Chief Counsel Memo Extends Deviation for Closing Some Easement BBA Cases (March 18, 2022)

Alerts/Articles

• Alert – Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships (December 10, 2015)
• Alert – IRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs (March 18, 2016)
• Article – US Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships and LLCs, Family Office Magazine (April 1, 2016)
• Article – IRS Seeks Comments for New Tax Examination and Collection Regime, International Law Office (April 8, 2016)
• Alert – IRS Issues First Partnership Audit Regulations (August 8, 2016)
• Alert – New Regulations Change Allocation of Partnership Liabilities (October 24, 2016)
• Alert – Congress Looks to Fix New Partnership Audit Rules (December 14, 2016)
• Alert – New Partnership Audit Rules Go Live (January 9, 2018)
• Article – INSIGHT: People, Places, and Things: Final Regulations on the Eligibility, Designation, Revocation, and Authority of Partnership Representatives, Bloomberg Tax: Daily Tax Report (September 11, 2018)
• Alert – Year-End Updates on Partnership Representatives (November 6, 2018)
• Article – EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year, Law360 (January 4, 2019)

Past & Upcoming Events

• 65th VA Conference on Federal Taxation – Ins and Outs of IRS Audits of Partnerships and S Corporations (June 7, 2013)
• Bloomberg BNA Webinar – New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Implications for Existing and Future Partnership and LLC Agreements (January 26, 2016)
• D.C. Bar Panel – Fundamental Partnership Audit Reform, Part 1 How It Happened? (February 2, 2016)
• Bloomberg BNA Webinar – New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Understanding the Nuances of the New Legislation (April 21, 2016)
• ABA Panel – Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015 (May 6, 2016)
• AICPA Webinar – New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships (May 16, 2016)
• D.C. Bar Panel – Fundamental Partnership Audit Reform, Part 2 What’s a Practitioner to Do? (June 23, 2016)
• D.C. Bar Panel – Exploring the Proposed BBA Partnership Audit Regulations (April 5, 2017)
• ABA Panel – Ethical Issues Regarding the Partnership Representative (October 5, 2018)
• Strafford Webinar – Partnership Representatives: New IRS Final Regulations Under Section 6223 and Challenges for Pass-Through Entities (January 30, 2019)