What Are Treasury's Deregulation and Burden Reduction Plans for BBA?

Tax attorney Lee Meyercord was quoted in a Tax Notes article analyzing the U.S. Department of the Treasury's plans to revisit regulations under the Bipartisan Budget Act of 2015's (BBA) centralized partnership audit regime as part of its 2025-2026 priority guidance plan. The article examined how potential changes aimed at deregulation and burden reduction, particularly around the calculation of imputed underpayments and treatment of non-income adjustments, could significantly reshape partnership audits and taxpayer compliance obligations. Ms. Meyercord emphasized the importance of practical refinements, including improvements to the imputed underpayment rules and broader netting of positive and negative adjustments, so that the system produces results partnerships view as accurate and manageable. She added she hopes the project reflects that IRS officials "are invested in a functioning, efficient BBA that produces an imputed underpayment that taxpayers are willing to pay because it is not significantly higher than what the partners would have paid."

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