IRS PMTA: Statute of Limitations for TEFRA, BBA Partnerships With Transition Tax Liabilities (IRC §965)

Chief Counsel’s Office advises on the period of limitations for adjustments related to tax code Section 965 for: (1) partnerships subject to the partnership procedures under Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA); (2) partnerships subject to the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA); (3) partnerships not subject to any consolidated procedures; and (4) taxpayers who are partners in partnerships not subject to TEFRA or BBA. The Chief Counsel’s Office outlines when the three-year or six-year statute of limitations applies. [PMTA 2020-008 (May 26, 2020)]

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