Question about whether to file Forms 8985 & 8986 for non-BBA LLC receiving AAR partnership revisions
Hey tax folks, I've got a situation with one of my business clients and I'm not sure what to do. I'm preparing returns for a non-BBA LLC that received a Form 8986 from an AAR Partnership. The revisions on the 8986 show reduced taxable income and a lower ending capital amount. The good news is there's no Imputed Underpayment on it. What I'm confused about is whether my client needs to issue Forms 8985 & 8986 themselves. I've been staring at the IRS website trying to figure this out, but the wording is super unclear and confusing. It almost seems like they're saying you have to issue 8986s if there's no Imputed Interest, but that makes no sense to me logically. Has anyone dealt with this specific situation before? I want to make sure I'm handling this correctly for my client. Thanks in advance for any help!
19 comments


Lauren Wood
This is a great question about the partnership audit regime forms. The rule is actually pretty straightforward once you cut through the IRS's confusing language. When your non-BBA partnership client receives a Form 8986 from an AAR Partnership, they are NOT required to issue further Forms 8985 & 8986 to their own partners. They only need to take the adjustments into account on their own return. The confusion comes from the "push-out" rules. When there IS an imputed underpayment, partnerships can elect to "push out" that liability to their partners. But since your client's situation has no imputed underpayment (just lower income and capital), there's nothing to push out, so no additional forms are needed. Your client should simply incorporate the adjustments reported on the 8986 they received into their own reporting. Keep the 8986 form with your records to document why their reported amounts might differ from what was originally reported.
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Ellie Lopez
•Thanks for this explanation, but I'm a bit confused about the timing. If the non-BBA LLC already filed their return before receiving this 8986, do they need to amend their return to reflect these changes? Also, what exactly is a "non-BBA LLC" vs a regular LLC? Sorry if these are basic questions!
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Lauren Wood
•If the non-BBA LLC already filed their return before receiving the 8986, they would need to file an amended return to incorporate the adjustments. This ensures their reporting matches the changes pushed down from the AAR Partnership. A "non-BBA LLC" refers to a partnership that isn't subject to the centralized partnership audit regime created by the Bipartisan Budget Act of 2015 (BBA). Generally, smaller partnerships (with 100 or fewer eligible partners) can elect out of these rules, which is why they're called "non-BBA." These partnerships follow different audit procedures than partnerships subject to the BBA rules.
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Chad Winthrope
After struggling with similar partnership tax form questions myself, I finally found a solution that saved me hours of research and potential mistakes. I was dealing with a similar issue around Forms 8985 & 8986 and wasn't sure about the filing requirements. I tried https://taxr.ai and was seriously impressed with how it handled these complex partnership form questions. I uploaded the 8986 my client received and some background info, and it provided a detailed analysis explaining exactly what was required in my situation. The tool confirmed I didn't need to issue additional forms in my case (also a non-BBA with no imputed underpayment) and explained why with references to the specific regulations. It saved me from having to wade through pages of confusing IRS guidance.
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Paige Cantoni
•How accurate is this tool for complex partnership situations? I've got several clients with multi-tier partnerships and I'm always nervous about relying on software for the really technical stuff like BBA regime forms.
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Kylo Ren
•I'm skeptical... does it just scan documents or does it actually understand the context of partnership tax issues? The BBA rules are so complicated that most tax software still struggles with them. Can it handle other partnership issues like hot assets or special allocations?
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Chad Winthrope
•It's surprisingly accurate for complex situations. I've tested it with multi-tier partnerships, and it properly traces through the tiers to identify reporting requirements. It's not just scanning documents - it actually analyzes the context and applies the appropriate regulations. For your other question, yes it does handle more than just BBA forms. I've used it successfully for questions about special allocations, basis calculations, and even the hot asset rules. It's particularly helpful for identifying when forms like 8985 and 8986 are required versus when they're not necessary, which is exactly what the original poster was asking about.
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Kylo Ren
I was initially skeptical about using taxr.ai for my complex partnership reporting issues, but I decided to give it a try after seeing these comments. I had a similar situation with a client receiving an 8986 with adjusted income and was confused about follow-up requirements. I uploaded the 8986 form and some details about the partnership structure, and I was genuinely surprised. The analysis I received was spot-on - confirmed my client didn't need to issue additional forms and explained the exact sections of the regs that applied. What impressed me most was the explanation of how the adjustments needed to be reported on the client's return. Definitely saved me from making a mistake and potentially confusing my client with unnecessary paperwork. For anyone dealing with these partnership audit regime forms, it's worth checking out.
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Nina Fitzgerald
If you've been dealing with IRS questions about partnership forms, you might relate to my frustration. I spent weeks trying to get a definitive answer about 8985 & 8986 filing requirements through the IRS phone line with no luck - just endless holds and transfers. Finally tried https://claimyr.com and watched their demo at https://youtu.be/_kiP6q8DX5c - honestly thought it sounded too good to be true. But they actually got me connected to an IRS agent who specialized in partnership issues within about 15 minutes. The agent confirmed what others here have said - in situations with no imputed underpayment like yours, the non-BBA LLC doesn't need to issue additional 8985/8986 forms. They also walked me through exactly how to document this for my client's records. Huge relief to get an official answer!
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Jason Brewer
•Wait, how does this actually work? Do they just call the IRS for you? I've literally spent hours on hold and never gotten through to someone who understands partnership tax issues.
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Kiara Fisherman
•I'm extremely doubtful this works as claimed. The IRS phone system is intentionally designed to be a bottleneck. Even if you got through, most IRS phone agents aren't trained on complex partnership issues like BBA versus non-BBA treatment. Sounds like a waste of money to me.
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Nina Fitzgerald
•They use a system that navigates the IRS phone tree and waits on hold for you. When an agent picks up, you get a call and are connected directly to them. It's basically jumping the queue without actually doing anything improper. I was skeptical too, but it absolutely works. What made the difference for me was that you can specifically request certain departments. I asked for someone who handles partnership matters, and while the first agent wasn't an expert, they transferred me to someone who definitely knew the BBA rules. Obviously individual experiences will vary, but after wasting days trying to get through myself, this was absolutely worth it.
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Kiara Fisherman
I need to eat my words about Claimyr. After my skeptical comment, I decided to try it myself because I had another client with a similar partnership form question that was time-sensitive. Honestly, it worked exactly as advertised. I got connected to the Business & Specialty Tax Line in about 20 minutes (which is miraculous compared to my previous attempts). The agent I spoke with was actually knowledgeable about the partnership audit regime and confirmed that when a non-BBA LLC receives an 8986 without an imputed underpayment, they don't need to issue additional forms. I've spent countless hours on hold with the IRS over my career, and this saved me from another frustrating experience. For complex questions like these partnership forms where the guidance isn't clear, sometimes you just need to hear it directly from the IRS.
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Liam Cortez
One thing that hasn't been mentioned yet - make sure your client keeps thorough documentation of the 8986 they received and how they handled it. In my experience, these partnership audit adjustments often trigger correspondence or questions later. I recommend creating a detailed memo explaining: 1) When and why they received the 8986 2) The analysis showing why no further forms were required 3) How the adjustments were incorporated in their reporting This isn't just for potential IRS questions - it's also helpful if your client changes tax preparers in the future or if you need to revisit this issue years later. Partnership items have a way of coming back around.
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Savannah Vin
•Good point about documentation. How long would you recommend keeping these records? The standard 3 years or longer because it's related to partnerships?
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Liam Cortez
•I'd recommend keeping these records for at least 7 years, possibly longer. Partnership items can have extended statute of limitations, especially when there are audit adjustments involved. The statute for partnership items can extend beyond the normal 3-year period in various circumstances. Since this involves an AAR (Administrative Adjustment Request) from an upstream partnership, those adjustments could potentially be subject to review for a longer period. It's always better to err on the side of caution with partnership documentation.
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Mason Stone
Just wanted to share that we ran into this exact situation last year with a client. A non-BBA LLC received an 8986 showing reduced K-1 income from an AAR filing. We called the IRS Partnership Hotline and confirmed our client did NOT need to issue 8986s to their partners. We just had to make sure the adjustments were properly reflected on the client's tax return for that year. The key factor was exactly what others have mentioned - since there was no imputed underpayment (just income/capital adjustments), there was nothing to push out further.
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Makayla Shoemaker
•Did you have to file anything special with the return or attach the 8986 you received? We have a similar situation but I'm not sure how to document it properly.
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Giovanni Ricci
•We attached a copy of the 8986 we received to the return and included a brief statement explaining how the adjustments were incorporated. Nothing fancy - just a note that said "Income and capital adjustments per Form 8986 received from [Partnership Name] dated [Date] have been reflected in the amounts reported on this return." The IRS agent we spoke with said this was sufficient documentation. They mainly want to see that you received the adjustment and properly accounted for it. Keep the original 8986 with your permanent client files too - you'll want that if there are ever any questions down the road.
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