Generally effective starting in 2018, the recently passed Bipartisan Budget Act of 2015 repeals the current TEFRA unified partnership audit procedures (TEFRA) and special rules relating to electing large partnerships (ELPs). The repeal of TEFRA represents the most significant change in the way that partnerships will be examined since the rules were first introduced in 1982. The purpose of the new partnership rules is to streamline partnership audits into a single set of rules for both the partners and the partnership. The new regime generally provides for assessment and collection of underpaid taxes, penalties and interest at the partnership level. The partnership may elect, however, to assign the assessment of underpaid amounts in the current year to those who were partners in the year to which the adjustment relates. Further, partnerships with 100 or fewer qualifying partners annually may opt out of the new rules, electing instead to be subject to audit at the level of each individual partner.