The Internal Revenue Service (IRS) reports that the first audits conducted under the Bipartisan Budget Act Centralized Partnership Audit Regime (BBA) are wrapping up, with assessments recently issued or forthcoming.  Although the BBA only became mandatory for the 2018 tax year, taxpayers could elect into the BBA regime for the 2016 and 2017 tax years.  Over the past year, the IRS has stressed that partnership audits would be a priority for the agency going forward.  To that end, it has hired at least 50 partnership audit specialists to staff its new Large Partnership Compliance Program ...

On April 14, 2021, the IRS released a memorandum clarifying that partners and partnership representatives of TEFRA or BBA partnerships are entitled to request and receive IRS administrative file records containing partnership returns and return information, including any supporting schedules, attachments, or lists which include identifying information of persons other than the requesting party.  This memorandum serves as guidance to taxpayers pending an update to the Internal Revenue Manual.

Internal Revenue Code section 6103(e) details which parties may access returns ...

A New Era of Partnership Representation Before the IRS

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