Page 25 - The TEFRA Partnership Audit Rules Repeal:
P. 25
TEFRA v. BBA—Comparison (cont.)
Rules Relating to Election to Push Out the Imputed Underpayment
TEFRA
• Not applicable under TEFRA
BBA
• Alternative payment option:
̶ Partnership can elect to issue amended statements to the partners of the “reviewed year”
̶ Election to do so must be made no later than 45 days after the date of notice of final partnership adjustment
̶ The partners must take into account their share of the adjustment in the reviewed year (and subsequent years as applicable) without rights to contest
̶ The partners are liable for any penalties
̶ Interest charged at underpayment rate + 2%
Copyright © 2016 Deloitte Development LLC. All rights reserved. Coming changes to IRS Audits of partnerships 16
