Under the BBA audit rules, the IRS no longer chases down individual partners for tax on audit adjustments. Instead, the partnership itself can be on the hook - leaving today’s partners paying for yesterday’s mistakes. This article breaks down how the rules work, including the imputed underpayment, the timing mismatch between the reviewed year and the adjustment year, the push-out election that can shift the burden back to reviewed-year partners, and provides some practice pointers.

The IRS has fundamentally changed how it audits partnerships - and every partnership, no matter how small, needs to pay attention. The Bipartisan Budget Act (BBA) created a centralized audit regime that shifts tax liability to the partnership itself, putting current partners at risk for past errors. This article explains the origin of the BBA, what it replaced, and the key actions every partnership should take to avoid costly surprises under the new audit rules.