e-News for BBA Partnerships Issue Number 2024-2

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e-News for BBA Partnerships 04/19/2024

Resources for BBA Partnerships:  

Tax Information for Partnerships

Modernized e-File (MeF) for Partnerships

Businesses with Employees

About Form 8980, Partnership Request for Modification of Imputed Underpayments Under IRC Section 6225 (c)

About Form 8985, Pass-Through - Statement Transmittal/Partnership Adjustment Tracking Report (Required under Sections 6226 and 6227)

About Form 8978, Partner's Additional Reporting Year Tax



Other Resources

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Issue Number:  2024-2

Inside This Issue

  1. BBA Centralized Partnership Audit Regime
  2. Designate or Change a Partnership Representative
  3. Elect Out of the Centralized Partnership Audit Regime
  4. File an Administrative Adjustment Request for a BBA Partnership
  5. BBA Partnership Audit Process
  6. Electronic Submission of Forms by Audited BBA Partnerships and Their Pass-Through Partners
  7. OFSS Status

1.  BBA Centralized Partnership Audit Regime


Links to the related BBA pages were added to the right side of the page to make it easier to navigate between pages.

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2.  Designate or Change a Partnership Representative


Complete page redesign:

Find how to designate or change a partnership representative for a partnership under the Bipartisan Budget Act (BBA) centralized partnership audit regime.

Enhanced section: 

How to change a partnership representative

Includes specific instructions for completing Form 8979 to revoke a partnership representative or designated individual, resign as a partnership representative or designated individual, and to designate a partnership representative. 

For details concerning completion of Form 2848 after a change in partnership representative, or generally how to complete the Form 2848 for BBA partnerships, with examples, see section:

How to authorize power of attorney (Form 2848)

To properly prepare Form 2848, please refer to IRM 4.31.9.7.10.1, Form 2848, For Items Within the Scope of the BBA Regime.

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3.  Elect Out of the Centralized Partnership Audit Regime


Links to the related BBA pages were added to the right side of the page to make it easier to navigate between pages.

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4.  File an Administrative Adjustment Request for a BBA Partnership


Renamed page. Links to the related BBA pages were added to the right side of the page to make it easier to navigate between pages.

Created new page with comprehensive example to aid in computing the imputed underpayment (IU). The link to the example and step-by-step instructions can be found in this section:

Figure and report an imputed underpayment (IU)

A BBA partnership must always include a computation of the IU, even when the IU is zero or less than zero, or the adjustments don't result in an IU.

The partnership should include documentation with the AAR that supports the computation.

If the calculated IU amount results in an amount greater than zero and the partnership doesn't elect to push out, it must report and pay the IU.

How to figure an imputed underpayment

PLEASE NOTE: in order to view the treatment of adjustment (8) "IRC 199A QBI" in the Residual grouping table in the example, be sure to use the scroll bar at the bottom of the table to view the column for Subgroup E. Adjustment (8) is positive but treated as zero: Under Treas. Reg. § 301.6225-1(b)(4), a partnership that files an AAR may treat a positive adjustment as zero if the positive adjustment is related to, or results from, a positive adjustment to another item. Therefore, in the example, the partnership can choose to treat adjustment (8) as zero.  

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5.  BBA Partnership Audit Process


Links to the related BBA pages were added to the right side of the page to make it easier to navigate between pages.

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6.  Electronic Submission of Forms by Audited BBA Partnerships and Their Pass-Through Partners


If you have problems downloading forms, email the PBBA Help Desk at LBI.BBA.eSubmit@irs.gov and we will email the blank official IRS forms to you. Please read form instructions completely before contacting the help desk for assistance with the upload and submission of BBA audit related forms.  

If you are new to the PBBA TCC and PBBA OFSS process, please review the link to the diagram in the section "to electronically submit BBA audit forms or request push out tracking numbers, follow these steps and see an action steps diagram."

Don't wait until the last minute. Give yourselves enough time to submit forms and the Service enough time to consider those submissions, countersign, or request corrections, if needed, before the expiration of your submission deadline.  Registering for online access and completing the PBBA TCC application can be a time-consuming process for some. You must wait 72 hours after issuance of the PBBA TCC or making changes to your PBBA TCC application or modifying your PIN before using the PBBA Online Form Submission Service (OFFS) or submissions will reject. As discussed under How to check the status of a form submissionyou MUST use the Receipt ID to check the submission status (accepted or rejected) of the submitted forms. If the submission was rejected, the forms in the submission are NOT considered to have been filed. Before the expiration of your submission deadline, a submission must be in “accepted status."

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7.  OFSS Status


No Update

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