The BBA procedures also fundamentally changed the process for amending Form 1065 and its Schedule K-1, Partner’s Share of Income, Deductions, Credits, etc. Thus, if an AAR were filed, the partners generally would not be able to take advantage of CARES Act benefits from an AAR until they file their current year returns, which could be in 2021.Īs noted by the IRS, the AAR process could significantly delay the relief provided in the CARES Act intended to apply to the affected tax years and provide an immediate benefit to taxpayers.Īs background, the BBA repealed the partnership audit provisions under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and introduced a new centralized audit regime for IRS audits of entities required to file Form 1065, U.S. …filing an AAR would result in the partners’ only being able to receive any benefits from that relief on the current tax year’s federal income tax return. Without the option to file amended returns by today’s revenue procedure, BBA Partnerships that already filed their Forms 1065 for the affected years generally would be required to file an AAR to take advantage of the CARES Act relief for partnerships. 116-136) (March 2020) provides retroactive tax relief that affects partnerships, including relief for the tax years ending in 2018, 2019, and in some cases 2020. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. 2020-23 exercises that authority to allow a partnership subject to the BBA to file an amended partnership return and issue amended Schedules K-1 under the circumstances described in the revenue procedure.
114-74) (November 2015) generally prohibits partnerships subject to the BBA (“BBA Partnerships”) from amending the information required to be furnished to their partners after the due date of the return, unless specifically provided by the Secretary of the Treasury or his delegate. The Bipartisan Budget Act of 2015 (BBA) (Pub.
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