e-News for BBA Partnerships Issue Number 2025-2

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e-News for BBA Partnerships 03/27/2025

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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All Forms & Instructions

Tax Professional Home

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Issue Number:  2025-2

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


NO UPDATE

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2.  Designate or Change a Partnership Representative


NO UPDATE

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3.  Elect Out of the Centralized Partnership Audit Regime


NO UPDATE

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4.  File an Administrative Adjustment Request for a BBA Partnership


Who files and signs an AAR

Only the reviewed year partnership representative (PR) or designated individual (DI) if the PR is an entity, can file and sign an AAR on behalf of the partnership. A partner can only file and sign an AAR on behalf of the partnership if they are also the PR.

The PR/DI is designated/appointed on the originally filed return or with a validly filed AAR. If no PR designation is in effect, including because of a failure to designate a PR on the originally filed Form 1065, the partnership (through an authorized person for the tax year) may submit Form 8979 to designate a PR. If the Form 8979 is submitted with an administrative adjustment request (AAR), the designation is treated as occurring prior to the filing of the AAR and effective on the date the AAR is filed.

You can designate or change a partnership representative when you file an AAR. The designation or change is effective on the date the AAR is filed.

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5.  BBA Partnership Audit Process

REMINDER: 

Forms 8985 and 8986 have been revised as of December 2024. Form instructions have also been revised as of December 2024. Please pay close attention to the column headings in Part IV of the Form 8985 and Part V of the Form 8986. The column headings in Part IV/Part V have been changed, and an "as corrected" column has been added. These columns require different figures than the Part IV/Part V columns in the previous revision of Form 8985 and 8986. If you received a Form 8986 “Rev. December 2019” version and you need to complete Forms 8985 and 8986 for your partners, you must complete the forms using the “Rev. December 2024” in the upper left-hand corner of the forms.

Corrected a typographical error in the following section:

Notice of administrative proceeding (NAP): Letters 5893 and 5893-A

The Notice of Administrative Proceeding (NAP) is a statutory notification required by Internal Revenue Code section 6231. The NAP informs the partnership and partnership representative that the IRS has started an administrative proceeding. This notice is similar to the Notice of Beginning Administrative Proceedings (NBAP) used in an examination subject to TEFRA procedures.

We issue the NAP about 30 days after we send Letter 2205-D. We mail the NAP to the partnership (Letter 5893) and the partnership representative (Letter 5893-A). We issue a separate NAP for each year under examination.

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


Use the BBA Online Form Submission Service (OFSS) to upload BBA audit forms and request push out tracking numbers. Complete Step 2: Apply for a PBBA TCC before you use the service. Please wait 72 hours after issuance of the PBBA TCC or making changes to your PBBA TCC application or modifying your PIN before moving on to Step 3, Use the BBA Online Form Submission Service.

If you submit forms during the 72-hour waiting period (to meet your submission deadline), you will receive the following error message: “ERROR: [Manifest-005] – Authorization to submit PBBA forms failed. The sign-on credentials entered are not correct per letter 6295C. Please correct and resubmit the form(s). If the problem persists, please contact us.” This message doesn’t mean you have to wait for the letter prior to submitting forms, but it does mean that the forms were rejected because they were submitted during the 72-hour waiting period. Although you were submitting the forms in order to meet your deadline, you must then resubmit after the waiting period and check the status of the form submission, making sure that the submission is in “accepted status.”

Audited BBA partnerships or pass-through partners with over 350 partners submitting push-out requests:  Request instructions at lbi.bba.esubmit@irs.gov. The submission of a large number of push out forms may result in a “connectivity error” message which means the connection is “timing out” before the Receipt ID can be displayed to the submitter. If you receive that error message, please check with us before attempting to resubmit the large file. 

REMINDER: Forms 8985 and 8986, as well as the Form 8980, have been revised as of December 2024. Form instructions and Pub 5346, Instructions for Form 8980, have also been revised as of December 2024. Please pay close attention to the column headings in Part IV of the Form 8985 and Part V of the Form 8986. These columns require different figures than the Part IV/Part V columns in the previous revision of Form 8985 and 8986. If you received a Form 8986 “Rev. December 2019” version and you need to complete Forms 8985 and 8986 for your partners, you must complete the forms using the “Rev. December 2024” in the upper left-hand corner of the forms.

HELPFUL HINT:  Some forms are rejecting due to the use of certain "special characters" in the partnership name (those in the formal name itself such as "&" or "-" are OK but don't include an apostrophe), addresses of partners, or in the Statements section of both Forms 8985 and 8986. DO NOT COPY AND PASTE from WORD or a similar application. IF you prepare information in the statement section in the PDF form itself, you can then copy and paste from that form to the other forms you are preparing (or use "save as" for each form being prepared), but do not copy from WORD or a similar application. (Apostrophes have been the most frequent cause of rejections.)

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7.  OFSS Status


NO UPDATE

Please contact the PBBA eSubmit Help Desk with questions or concerns. (813)367-8037 or LBI.BBA.eSubmit@irs.gov

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