The stodgy world of partnership audit and tax collection is headed for a seismic change! Get ready to say bye-bye to the current Tax Equity and Responsibility Act of 1982 (TEFRA) and Electing Large Pa…
Dig into the New Partnership Tax Rules
In Brief
- Title XI of the of the BBA is Congress’s response to complex partnership structures that make it difficult for the IRS to reach the ultimate business owners and their assets.
- Partners should incorporate the new BBA terminology and rules into their partnership agreements and determine whether to include provisions concerning the 6221 and 6226 election.
- Partners should also vigilantly review the partnership’s current and previous tax records to determine the likelihood of being liable for any imputed tax underpayment under the new rules.
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