Understanding the BBA Partnership Audit Rules 2026
Practising Law Institute (PLI)
Entrance on 45th Street
New York, New York 10036
Tax attorney Lee Meyercord will speak at the Practising Law Institute's (PLI) Understanding the BBA Partnership Audit Rules 2026 program, which will unpack how the Bipartisan Budget Act of 2015 (BBA) changed the procedures for partnership audits. Presentations will explore the BBA's new approach to adjustments in the partnership context, including when partners may be liable and how much they may owe, how to identify the party bearing the risk of an adjustment, what BBA-related issues may arise in transactional due diligence and how to draft BBA provisions in partnership agreements under the new regulations.
Ms. Meyercord will speak on two panels during the day-long event. Her first panel will focus on modification procedures under Section 6225(c) and the Section 6226 push out election, two major ways to resolve an adjustment under the BBA. She will describe the pros and cons of each option along with how the IRS is implementing modification procedures. Her second panel will review the steps in a BBA audit, from the role of the IRS Office of Appeals to key deadlines to calendar. The presentation will also cover how to calculate interest, how to determine the statute of limitations, when penalties apply and how to defend against them, and what other issues may arise in BBA audits.
Session Times and Topics
Other Choices Under the BBA Partnership Audit Rules – Modification and Push Out Election
10:45 a.m. ET
BBA Partnership Audit Rules – Controversy and Procedure
1:30 p.m. ET