BBA Audit Procedures for Tax Counsel: IRS Enforcement Actions, Pitfalls to Avoid, Successor Liability, and More

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Tuesday, December 1, 2020

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE/CPE course will provide tax professionals and advisers guidance on Bipartisan Budget Act (BBA) audit procedures and rules and recent IRS enforcement actions and guidance. The panel will describe the partnership audit processes in detail, outlining the changes that facilitate IRS audits of partnerships. The speakers will offer concrete suggestions on managing BBA audits, pitfalls to avoid, taxpayer rights, and other vital items.


The IRS Large Business and International Division stated in its most recent Focus Guide that an increase in partnership audits is underway. Tax professionals must identify critical issues for partnerships subject to BBA audit rules and implement strategies for managing these audits and minimize potential tax liability and penalties.

The BBA centralized partnership audit regime replaced the Tax Equity and Fiscal Responsibility Act audit procedures and the electing large partnership rules. Under the BBA centralized partnership audit regime, the IRS generally assesses and collects any tax understatement at the partnership level. Under the BBA audit rules, many partnerships are subject to an entity-level audit by default.

A partnership is subject to BBA centralized partnership audit rules unless it is an eligible partnership and makes an annual election out of BBA on a timely filed Form 1065. An eligible partnership is one with 100 or fewer partners, all of whom are either individuals, C corporations or foreign entities treated as a C corporation if it were domestic, S corporations, or estates of deceased partners.

Listen as our panel of experienced tax attorneys discusses BBA audit procedures, recent IRS enforcement actions, and concrete suggestions on managing BBA audits, taxpayer rights, and other critical items.



  1. BBA centralized partnership audit rules
  2. Compliance procedures to minimize chances of an audit
  3. A step-by-analysis of a BBA audit
  4. Navigating BBA audit procedures and pitfalls to avoid


The panel will review these and other key issues:

  • What are the compliance challenges of partnerships subject to BBA audits?
  • What are the compliance best practices to limit the possbility of being selected for a BBA audit?
  • What are strategies for handling a BBA audit?
  • What are the pitfalls to avoid under the BBA procedures and rules?


Horwitz, Robert
Robert Horwitz

Hochman Salkin Toscher Perez

Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil...  |  Read More

Kalinski, Jonathan
Jonathan Kalinski

Hochman Salkin Toscher Perez

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including...  |  Read More

Stein, Michel
Michel R. Stein

Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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