Congress Repeals the Tefra Partnership Audit Rules and Enacts a New Set of Rules Which Includes the Assessment of Income Taxes at the Partnership Level

As part of The Bipartisan Budget Agreement of 2015, which the President signed into law on November 2, 2015, Congress repealed the complex and much-criticized partnership entity-level audit (“ELA”) rules under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”), including the electing large partnership rules. The new law replaces the ELA rules with a set of “streamlined” entity-level audit (“SELA”) rules designed to enhance the IRS’s ability to audit more large partnerships and increase tax collections.