The “Bipartisan Budget Act of 2015″ (the “BBA”) made sweeping changes to the rules governing IRS audits of partnerships and LLC’s filing as partnerships, changes that are finally scheduled to take effect January 1, 2018. With the regulatory freeze on these rules now lifted,  the IRS recently reissued proposed regulations, giving us much needed guidance in implementing the new rules. While  these rules were enacted to streamline the IRS’s partnership audit and collection process, the new rules will require that most existing partnerships  consider electing out of the new rules or revising their partnership agreements to address the BBA.