Different deadlines apply to audited and pass-through partnership push-out statements

Plain-English summary

Chief Counsel advised on the deadlines for furnishing push-out statements under the centralized partnership audit rules. An audited partnership must furnish its statements within 60 days after the adjustments become finally determined. A pass-through partner has until the extended due date of the audited partnership's adjustment-year return to furnish its statements. If the pass-through partner does not furnish the statements by that deadline, it must pay the imputed underpayment.

Ruling snapshot

• Question: When must an audited partnership and its pass-through partners furnish push-out statements?
• Outcome: Advice given
• Key authorities: IRC § 6226(b)(4)(B); Treas. Reg. §§ 301.6226-2(b) and 301.6226-3(e)(3)(ii)

Full text (IRS public release)

ID:          CCA_2021081816580943
UILC:        6226B.00-00

Number: 202139009
Release Date: 10/1/2021
From: --------------------
Sent: Wednesday, August 18, 2021 4:58:09 PM
To: ----------------------
Cc:
Bcc:
Subject: RE: Deadline, Push Out Statements By BBA Pass-Through Partners


The audited partnership has to furnish statements within 60 days of when the adjustments become
finally determined. 301.6226-2(b). The pass through partner has until the extended due date of the
audited partnership's adjustment year return to furnish statements (or pay the IU if they fail to furnish).
See 6226(b)(4)(B), 301.6226-3(e)(3)(ii).

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