The AICPA noted that with the Coronavirus Aid, Relief and Economic Security (CARES) Act, the IRS granted relief under Rev. Proc. 2020-23, that allows eligible Bipartisan Budget Act (BBA) partnerships to file amended returns, instead of administrative adjustment requests when making adjustments to 2018 and/or 2019 returns.
“Partnerships need additional time to determine which regulations they may want to apply that were just released under section 163(j) and section 1061, and they need the increased cash flow to take advantage of the provisions in the CARES Act,” Chris Hesse, chair of the AICPA Tax Executive Committee, wrote in a letter to the IRS and the Treasury Department.
Final and proposed regulations under section 163(j) were released on July 28 and those under section 1061 were released on July 31.