George Hani was quoted regarding the Bipartisan Budget Act of 2015 (BBA). He discussed the BBA with Holly Paz, director (passthrough entities), Internal Revenue Service (IRS) Large Business and International Division at the Parker C. Fielder Oil and Gas Tax Conference. The ability to elect out of the BBA has been a significant issue, Hani said. Many commenters requested that the list of eligible partners that may elect out be expanded, so what standards are being applied "to see which entities might be more likely to be included on the list?," he said. A significant change in the BBA from the partnership audit rules under the 1982 Tax Equity and Fiscal Responsibility Act (TEFRA) is the "amount of authority vested in the partnership representative. The proposed regs also lack the notice rights afforded to partners under TEFRA," Hani said, adding that "those are all gone in the BBA, so now . . . the IRS has one point of contact, the partnership representative, and everything else is between the partnership and its partners." A partnership must be careful when selecting its partnership representative and when drafting the partnership agreement to incorporate the rights that it wants, he said, adding that the proposed regs state that "even if the partnership representative does something that's beyond his authority under state law, the IRS will still respect that."