BBA Audits: What Tax Attorneys Need to Know

The session will provide an in-depth look at how the Bipartisan Budget Act (BBA) has transformed partnership audits, including the centralized partnership audit procedures under IRC §§ 6221–6241. Jennifer Black (Citrin Cooperman) and Robert Horwitz (Hochman Salkin Toscher Perez, P.C.) will guide attendees through the key components of a BBA audit—from the designation and powers of the Partnership Representative, to the calculation and modification of imputed underpayments, to the decision-making process between paying at the partnership level versus electing a push-out.

The program will also cover the mechanics and strategy behind Administrative Adjustment Requests (AARs), the strict timing rules and procedural traps, and how tiered partnership structures complicate compliance and reporting. Whether you advise on partnership formation, prepare partnership returns, or represent clients before the IRS, this presentation will deliver essential tools for navigating the BBA regime in practice.