Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan Budget Act of 2015 (“BBA”). Although the provisions of the BBA are extremely complex and relatively untested, the IRS continues to add additional clarity and color on many of its provisions through the publication and release of final and proposed regulations. On November 24, 2020, the IRS published in the Federal Register additional proposed regulations under the BBA relating to, among other things, “special enforcement matters.” See REG-123652-18.
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