Key Takeaways The BBA centralized partnership audit regime allows the IRS to assess and collect tax adjustments at the partnership level rather than from individual partners The partnership representative has binding authority over all partners during the audit process Push-out elections allow partnerships to shift adjusted tax liabilities to individual partners Modification procedures can significantly reduce the imputed underpayment amount Professional representation from experienced tax defense professionals is essential for navigating these complex rules Overview of the Bipartisan Budget Act Partnership Audit Rules The Bipartisan Budget Act of 2015 (BBA) created a new centralized partnership audit regime that took effect for partnership tax years beginning after December 31, 2017. This regime replaced the Tax Equity and Fiscal Responsibility Act (TEFRA) partnership audit procedures and the electing large partnership rules that had governed partnership audits for decades. The BBA fundamentally changed the landscape of partnership tax controversy by shifting the focus from individual partner-level adjustments to entity-level assessments. Under the prior TEFRA rules, the IRS would determine partnership items at the partnership level but then assess and collect any resulting tax from individual partners. This process was administratively burdensome for the IRS, particularly for large partnerships with hundreds or thousands of partners. The BBA addressed this by creating a streamlined process where the IRS can assess and collect an "imputed underpayment" directly from the partnership entity. This change has profound implications for partnership tax planning, partnership agreement drafting, and audit defense strategy. At Neil Jesani Tax Resolution , we help partnerships and their partners navigate these complex rules to minimize tax liability and protect their interests throughout the audit process. The Centralized Partnership Audit Regime How It Works Under the centralized partnership audit regime, the IRS conducts partnership examinations at the entity level and issues a Notice of Proposed Partnership Adjustment...