Under the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015, adjustments to partnership-related items are determined at the partnership level under Code § 6225. However, under Code § 6226, the partnership may elect to “push out” the imputed underpayment so that the tax attributable to the adjustments is assessed and collected from the partnership’s partners. The election to “push out” the imputed underpayment under Code § 6226 must be made within 45 days of date on which the final partnership adjustment is mailed by the IRS. The election, once made, may only be revoked with the consent of the IRS.
Last week, the IRS published Form 8988, Election for alternative Payment of the Imputed Underpayment and Form 8989, Request to Revoke the Election for Alternative to Payment of the Imputed Underpayment, to assist taxpayers in implementing Code § 6226.
IRS issues forms to make, and to revoke, partnership audit “push out” election. CheckPoint Daily Updates 2/11/2019. Federal Tax Update.