{"abstract":"This document contains proposed regulations regarding implementation of section 1101 of the Bipartisan Budget Act of 2015 (BBA), which was enacted into law on November 2, 2015. Section 1101 of the BBA repeals the current rules governing partnership audits and replaces them with a new centralized partnership audit regime that, in general, assesses and collects tax at the partnership level. These proposed regulations provide rules for partnerships subject to the new regime, including procedures for electing out of the centralized partnership audit regime, filing administrative adjustment requests, and the determination of amounts owed by the partnership or its partners attributable to adjustments that arise out of an examination of a partnership. The proposed regulations also address the scope of the centralized partnership audit regime and provide definitions and special rules that govern its application, including the designation of a partnership representative. The proposed regulations affect partnerships for taxable years beginning after December 31, 2017 and any partnerships that elect application of the centralized partnership audit regime pursuant to Sec. 301.9100-22T for taxable years beginning after November 2, 2015 and before January 1, 2018. This document also provides notice of a public hearing on these proposed regulations. This document also withdraws the notice of proposed rulemaking published in the Federal Register on February 13, 2009 (74 FR 7205), regarding the conversion of partnership items related to listed transactions.","action":"Notice of proposed rulemaking, notice of public hearing, and withdrawal of notice of proposed rulemaking.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2017/06/14/2017-12308.html","cfr_references":[{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"82 FR 27334","comment_url":null,"comments_close_on":"2017-08-14","correction_of":null,"corrections":[],"dates":"Written or electronic comments must be received by August 14, 2017. Outlines of topics to be discussed at the public hearing scheduled for September 18, 2017, at 10 a.m. must be received by August 14, 2017.","disposition_notes":null,"docket_ids":["REG-136118-15"],"dockets":[{"supporting_documents":[],"agency_name":"IRS","documents":[{"comment_count":35,"comment_start_date":"2017-06-14","updated_at":"2023-02-28T19:07:47.636-05:00","comment_url":"https://www.regulations.gov/commenton/IRS-2017-0009-0001","allow_late_comments":null,"id":"IRS-2017-0009-0001","comment_end_date":"2017-08-15","regulations_dot_gov_open_for_comment":false}],"supporting_documents_count":0,"id":"IRS-2017-0009","title":"Centralized Partnership Audit Regime (REG-136118-15)"}],"document_number":"2017-12308","effective_on":null,"end_page":27402,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2017/06/14/2017-12308.xml","html_url":"https://www.federalregister.gov/documents/2017/06/14/2017-12308/centralized-partnership-audit-regime","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2017-12308?publication_date=2017-06-14","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2017-06-14/2017-12308/mods.xml","not_received_for_publication":null,"page_length":69,"page_views":{"count":5119,"last_updated":"2026-09-21 06:15:03 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2017-06-14/pdf/2017-12308.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2017-12308.pdf?1497357959","publication_date":"2017-06-14","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2017/06/14/2017-12308.txt","regulation_id_number_info":{"1545-BN77":{"issue":"201710","html_url":"https://www.federalregister.gov/regulations/1545-BN77/centralized-partnership-audit-regime","title":"Centralized Partnership Audit Regime","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201710&RIN=1545-BN77&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BN77"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BN77/centralized-partnership-audit-regime","title":"Centralized Partnership Audit Regime"},"comments_count":35,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2017-0009","supporting_documents_count":0,"docket_id":"IRS-2017-0009","document_id":"IRS-2017-0009-0001","regulation_id_number":"1545-BN77","title":"Centralized Partnership Audit Regime (REG-136118-15)","checked_regulationsdotgov_at":"2023-03-01T00:07:46Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":27334,"subtype":null,"title":"Centralized Partnership Audit Regime","toc_doc":"Centralized Partnership Audit Regime","toc_subject":null,"topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":82}