The Bipartisan Budget Act of 2015 (BBA), results in a significant change to the way the IRS audits partnerships and limited liability companies that are treated as partnerships for tax purposes. The new rules will replace the current Tax Equity And Fiscal Responsibility Act of 1982 (TEFRA) unified partnership audit rules along with the electing large partnership (ELP) rules, in favor of a more streamlined audit regime, namely: allowing the IRS to audit partnerships and their