In the Bipartisan Budget Act of 2015 (the Bipartisan Budget Act) Congress completely overhauled the procedures for examining partnership returns, litigating disputes, and collecting resulting deficiencies.
Postured as a revenue raiser, the Bipartisan Budget Act promises additional revenue of $9.3 billion over 10 years, based on increased collections resulting from streamlined partnership audit rules (the New Rules). The Bipartisan Budget Act repeals the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) audit rules as well as the ‘‘electing large partnership (ELP) rules’’ enacted in 1997 and replaces them with this simplified regime for taxable years beginning after December 31, 2017.