{"abstract":"This document contains proposed regulations implementing 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 addressing how pass-through partners take into account adjustments under the alternative to payment of the imputed underpayment described in section 6226 and under rules similar to section 6226 when a partnership files an administrative adjustment request under section 6227. To make corresponding changes, these proposed regulations amend portions of the previously proposed regulations under sections 6226 and 6227. Additionally, these proposed regulations provide rules regarding assessment and collection, penalties and interest, and period of limitations under the new centralized partnership audit regime. The proposed regulations also address the rules for seeking judicial review of partnership adjustments.","action":"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/2017/12/19/2017-27071.html","cfr_references":[{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"82 FR 60144","comment_url":"https://www.regulations.gov/commenton/IRS-2018-0001-0001","comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by March 19, 2018.","disposition_notes":null,"docket_ids":["REG-120232-17","REG-120233-17"],"dockets":[{"supporting_documents":[],"agency_name":"IRS","documents":[{"comment_count":4,"comment_start_date":"2017-12-19","updated_at":"2024-11-06T21:52:42.540-05:00","comment_url":"https://www.regulations.gov/commenton/IRS-2018-0001-0001","allow_late_comments":true,"id":"IRS-2018-0001-0001","comment_end_date":"2018-03-20","regulations_dot_gov_open_for_comment":false}],"supporting_documents_count":0,"id":"IRS-2018-0001","title":"Centralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and\nAdministrative and Procedural Provisions (REG–120232–17; REG–120233–17)"}],"document_number":"2017-27071","effective_on":null,"end_page":60167,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2017/12/19/2017-27071.xml","html_url":"https://www.federalregister.gov/documents/2017/12/19/2017-27071/centralized-partnership-audit-regime-rules-for-election-under-sections-6226-and-6227-including-rules","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2017-27071?publication_date=2017-12-19","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2017-12-19/2017-27071/mods.xml","not_received_for_publication":null,"page_length":24,"page_views":{"count":3129,"last_updated":"2026-09-21 14:15:06 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2017-12-19/pdf/2017-27071.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2017-27071.pdf?1513354523","publication_date":"2017-12-19","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2017/12/19/2017-27071.txt","regulation_id_number_info":{"1545-BO04":{"issue":"201810","html_url":"https://www.federalregister.gov/regulations/1545-BO04/centralized-partnership-audit-regime-procedural-provisions","title":"Centralized Partnership Audit Regime--Procedural Provisions","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201810&RIN=1545-BO04&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"},"1545-BO03":{"issue":"201810","html_url":"https://www.federalregister.gov/regulations/1545-BO03/rules-related-to-the-centralized-partnership-audit-regime","title":"Rules Related to the Centralized Partnership Audit Regime","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201810&RIN=1545-BO03&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BO03","1545-BO04"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BO03/rules-related-to-the-centralized-partnership-audit-regime","title":"Rules Related to the Centralized Partnership Audit Regime"},"comments_count":4,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2018-0001","supporting_documents_count":0,"docket_id":"IRS-2018-0001","document_id":"IRS-2018-0001-0001","regulation_id_number":"1545-BO03","title":"Centralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and\nAdministrative and Procedural Provisions (REG–120232–17; REG–120233–17)","checked_regulationsdotgov_at":"2024-11-08T00:55:11Z"},"regulations_dot_gov_url":"https://www.regulations.gov/commenton/IRS-2018-0001-0001","significant":false,"signing_date":null,"start_page":60144,"subtype":null,"title":"Centralized Partnership Audit Regime: Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural Provisions","toc_doc":"Rules for Election Under Sections 6226 and 6227, Including Rules for Tiered Partnership Structures, and Administrative and Procedural Provisions","toc_subject":"Centralized Partnership Audit Regime:","topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":82}