![]() ![]() 2021-29 on the amended return and write “FILED PURSUANT TO REV PROC 2021-29” at the top of the return and attach a statement with each Schedule K-1 furnished to its partners with the same notation. The BBA partnership must clearly indicate the application of Rev. In order to take advantage of the option to file an amended return, a BBA partnership must file a Form 1065 (with the "Amended Return" box checked) and furnish corresponding amended Schedules K-1. For more information, please refer to tax alert on Rev. 2021-28 for changing a taxpayer’s method of accounting that might be less burdensome to taxpayers. If an eligible BBA partnership would like an alternative to amending a tax return, there are alternative procedures set forth in Rev. Once the tax changes under TCDTRA have been taken into account, or a late section 163(j)(7) election has been made, eligible BBA partnerships may make any changes to their amended returns. To be eligible to file an amended return under this relief, a partnership must be one of the following: a holder of residential rental property that chooses to change either or both of their method of depreciation or general asset account treatment for such property, pursuant to section 202 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the TCDTRA), or choosing to make a late section 163(j)(7) (real property trade or business) election. This revenue procedure exercises that authority to allow eligible BBA partnerships to file amended partnership returns and furnish amended Schedules K-1 to their partners. 31, 2017, unless specifically authorized. ![]() After that date, those eligible BBA partnerships must once again follow BBA Administrative Adjustment Request (‘AAR’) procedures (similar relief was granted last year, refer to: our previous alert published on April 8, 2020).īBA Partnerships are generally prohibited from filing amended returns for tax years beginning after Dec. This window of opportunity applies to partnership years that began in 2018, 2019 or 2020, and is open through Oct. 2021-29, which authorizes the filing of amended returns by a narrow class of eligible BBA partnerships (those subject to the new partnership procedural rules) that were previously prohibited from doing so. ![]() To take advantage of the relief provided by Revenue Procedure 2019-32, the partnership should file a superseding Form 1065 and furnish corresponding Schedules K-1 in the same manner as the original return and Schedules K-1 and write on the top of the superseding Form 1065 “SUPERSEDING FORM 1065 PURSUANT TO REVENUE PROCEDURE 2019-32.” The superseding return replaces any prior return for the taxable year for purposes of determining the partnership’s treatment of partnership-related items.įor more information or questions you may have, reach out to Michael Elliot, or your trusted Cherry Bekaert professional.The IRS has issued Rev. The practical effect of the revenue procedure is such that the IRS will treat timely filing of Form 1065 as a timely and appropriately filed request for a six-month extension of the deadline to file Form 1065.
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