1545-BN33 201804 Unified Agenda of Federal Regulatory and Deregulatory Actions 1545 Internal Revenue Service IRS 1500 Department of the Treasury TREAS Early Election Into the Partnership Audit Regime Under the Bipartisan Budget Act of 2015

Under section 1101(g)(4) of Public Law 114-74, a partnership may elect (at such time and in such form and manner as the Secretary of the Treasury may prescribe) for certain amendments under Public Law 114-74, section 1101 to apply to any return of a partnership filed for a partnership taxable year beginning after November 2, 2015 (the date of the enactment of the BBA) and before January 1, 2018. This proposed regulation provides the time, form, and manner of the election.

]]> Substantive, Nonsignificant Previously Published in The Unified Agenda Final Rule Stage No No Other 26 CFR 31 26 U.S.C. 7805 Pub. L. 114-74, sec. 1101(g)(4) No NPRM by Cross-Reference to Temporary Regulations 08/05/2016 81 FR 51835 NPRM by Cross-Reference to Temporary Regulations Comment Period End 10/04/2016 Final Action 12/00/2018 REG-105005-16 (NPRM) Drafter attorney: Jennifer Black (202) 317-5216 Reviewer attorney: Gregory Armstrong (202) 317-5131 Treasury attorney: Rochelle Hodes (202) 622-1787 CC:PA:Branch 7 No Businesses None No No No No Jennifer Black Attorney 1545 Internal Revenue Service IRS 202 317-5216 jennifer.m.black@irscounsel.treas.gov 1111 Constitution Avenue NW., Washington DC 20224