BBA Partnership Audit 2026: Form 8986 Push-Out Deadline
If a partnership you invest in filed an AAR — or the IRS finished a BBA examination and issued a Form 8986 — the clock is now running for every downstream partner. In our practice at SW Accounting & Consulting Corp, this is one of the most under-planned deadlines in partnership tax. The BBA partnership audit push-out rules can force a pass-through partner to file, pay, and re-issue Forms 8986 to its own partners inside a tight window — and getting it wrong can trigger imputed underpayments the entity has to eat.
Below is what the IRS is telling pass-through partners for the current cycle, why the September 15, 2026 date matters, and the practical filing and portal-maintenance details you need to know before the last week of August.
What is the BBA partnership audit regime, and why do pass-through partners get pulled in? 🧾
The Bipartisan Budget Act of 2015 centralized how partnerships are audited: the IRS assesses adjustments at the partnership level, and the partnership either pays an imputed underpayment or pushes the adjustments out to its reviewed-year partners.
Under the centralized BBA partnership audit regime, when the IRS proposes adjustments — or when the partnership itself files an Administrative Adjustment Request (AAR) — the source partnership can elect a “push-out” under IRC §6226. Instead of the partnership paying the imputed underpayment, the reviewed-year partners are furnished a Form 8986 and pick up the adjustment on their own returns.
When any of those reviewed-year partners is itself a partnership or other pass-through entity — a fund-of-funds structure, tiered LLC, or an S corporation partner — that entity becomes a “pass-through partner.” Pass-through partners have a stark choice: pay the imputed underpayment themselves, or push the adjustment further down to their partners by preparing their own Form 8985 and Forms 8986. Either way, the paperwork does not go away — it moves.
What is the pass-through partner deadline in the BBA partnership audit push-out chain? ⏰
For a pass-through partner that received a Form 8986 tied to a BBA partnership audit or AAR, the IRS notes the pay-or-push-out deadline may fall on September 15, 2026 — with the controlling date printed in Part II, F of the Form 8986 itself.
The IRS reminded pass-through partners in its recent BBA update that if you received a Form 8986 as a pass-through partner, the deadline to pay or push out further may be 9/15/2026 — and the taxpayer must confirm the exact date on Part II, F of the form. That date is the trigger for two independent actions:
- Furnish a Form 8986 to each reviewed-year partner of the pass-through partner (i.e., push down one more tier), and
- Submit a Form 8985 transmittal, together with all Forms 8986, to the IRS by that date.
There is no informal extension. If the pass-through partner’s submission is not in “accepted” status by the deadline, the next tier of partners cannot get their own pushouts accepted, and the whole chain begins to backlog.
How do you actually submit Forms 8985 and 8986 to the IRS? 📠
The IRS accepts BBA pass-through submissions three ways — fax, mail, or the PBBA OFSS portal — with a strict 100-page cutoff between fax and mail and mandatory e-submission for audited BBA partnerships.
The IRS instructions for a Form 8985 transmittal package are precise, and the wrong channel can cause the submission to be rejected outright:
- Submission 100 pages or less: fax to 888-981-6982. This fax number is only for Forms 8985 and 8986 — general BBA correspondence sent there will not be processed.
- Submission over 100 pages: mail to Ogden – Internal Revenue Submission Processing Center M/S 4705, 1973 N Rulon White Blvd., Ogden, UT 84201.
- Do not batch to beat the fax cap. The IRS is explicit: a single source partnership and reviewed-tax year must be transmitted on one Form 8985 with all related Forms 8986 attached. You cannot split 35 Forms 8986 across multiple 8985s to squeeze under the 100-page limit.
For pass-through partners that received a Form 8986 tied to an audited BBA partnership (rather than an AAR), submission must go through the PBBA OFSS e-submission portal. If you are new to the PBBA TCC application process or the OFSS portal, the IRS page walks through the steps — and you should not attempt those steps a week before the deadline. TCC applications and portal onboarding can take time to clear.
Why does the PBBA OFSS portal maintenance schedule matter right now? 🛠️
The IRS has announced two scheduled outages of the PBBA OFSS portal that fall inside the September 15, 2026 push-out window — miss those windows and you may miss your deadline.
According to the current IRS BBA notice, the PBBA OFSS portal will be unavailable during two maintenance windows:
- Tuesday, August 25, 2026 at 5:00 p.m. ET → Thursday, August 27, 2026 at 8:00 p.m. ET.
- Tuesday, September 22, 2026 at 5:00 p.m. ET → Thursday, September 24, 2026 at 8:00 p.m. ET.
The August window falls three weeks before the September 15 deadline — inconvenient, but survivable if planned around. The September window falls after the September 15 deadline but before many tiered filings need to clear. The IRS is blunt in the notice: do not wait until the last minute, because a submission must be in “accepted status” before the deadline expires. A submission uploaded on the evening of September 14 that has not cleared processing by September 15 will not save the day.
BBA partnership audit push-out at a glance 📊
| Item | Detail | Watch item |
|---|---|---|
| Pass-through partner deadline | May be Sept. 15, 2026 | Confirm on Part II, F of your Form 8986 |
| Fax route | ≤ 100 pages → 888-981-6982 | Only for Forms 8985/8986 |
| Mail route | > 100 pages → Ogden, UT 84201, M/S 4705 | No batch-splitting for the same source/year |
| Audited BBA e-submission | PBBA OFSS portal (irs.gov/bbaeSubmit) | TCC application onboarding is not instant |
| OFSS maintenance | Aug 25–27 & Sept 22–24, 2026 (ET) | Portal offline; plan around it |
| Common error | F8985-040 | Upstream tier must be “accepted” first |
What should a pass-through partner do this week? ✅
Identify every Form 8986 you have received, calendar the Part II, F date, and plan submission channel and timing around the OFSS maintenance windows.
Concrete steps to take before the last week of August:
- Pull every Form 8986 you received for reviewed years and read Part II, F on each — the deadline is per-form, not per-partnership.
- Decide pay vs. push out. If the pass-through partner absorbs the imputed underpayment, the paperwork stops here. If it pushes out further, prepare a Form 8985 transmittal plus a Form 8986 for each of your own reviewed-year partners.
- Count pages. Under 100 pages → fax to 888-981-6982; over 100 → mail to Ogden. Do not split a single source-partnership/reviewed-year package to game the fax cap — it will be rejected.
- For audited BBA partnerships, use OFSS. Confirm your PBBA TCC is active and your role assignments are in place well before September 15, and do not attempt any submission during the Aug 25–27 or Sept 22–24 outage windows.
- Coordinate with upstream tiers. If your Form 8986 came from a pass-through, confirm their submission is in “accepted” status before you attempt to file, or you will hit error F8985-040.
📌 Key Takeaways
- The BBA partnership audit push-out deadline for pass-through partners is on the face of Form 8986 (Part II, F) — often Sept 15, 2026.
- Under 100 pages → fax to the dedicated IRS line; over 100 → mail to Ogden. No batching.
- Audited BBA submissions must go through the PBBA OFSS portal; TCC access takes time.
- OFSS maintenance: Aug 25–27 and Sept 22–24, 2026 — plan around them.
- Error F8985-040 means the upstream tier isn’t “accepted” yet — call before you resubmit.
Frequently Asked Questions ❓
Q. Where exactly is my BBA partnership audit push-out deadline printed?
The controlling date is in Part II, F of the Form 8986 you received. The IRS notes the deadline may fall on 9/15/2026 for the current cycle, but the actual date on your specific form governs.
Q. Do I have to push out, or can I just pay?
A pass-through partner may pay the imputed underpayment at its level (and stop the chain there) or push the adjustments out further to its own reviewed-year partners by furnishing them Forms 8986. Both routes require timely action by the Form 8986 deadline.
Q. My package is 109 pages. Can I split the Forms 8986 across two Form 8985 transmittals to fax under the 100-page cap?
No. The IRS states that a single source partnership and reviewed-tax year must be submitted on one Form 8985 with all related Forms 8986. A 109-page package must be mailed to Ogden, not split for fax.
Q. What is the PBBA OFSS portal, and when do I have to use it?
The PBBA OFSS portal (irs.gov/bbaeSubmit) is the IRS e-submission channel for pass-through partners that received Forms 8986 tied to an audited BBA partnership. New users must first apply for a PBBA TCC — that onboarding is not instant, so start well before the deadline.
Q. What does error F8985-040 mean?
F8985-040 means the pass-through partner that furnished Forms 8986 to you must electronically file those forms with the IRS first, and they must be in “accepted” status before your pushout forms can be accepted. Confirm the upstream status before resubmitting.
Q. When is the PBBA OFSS portal down for maintenance?
Two scheduled outages: Aug 25, 2026 (5:00 p.m. ET) through Aug 27, 2026 (8:00 p.m. ET), and Sept 22, 2026 (5:00 p.m. ET) through Sept 24, 2026 (8:00 p.m. ET). Do not plan submissions during these windows.
The BBA push-out chain is unforgiving of last-minute filers. If your partnership received an AAR pass-through package this year, or your fund-of-funds structure sits mid-chain in a BBA examination, contact SW Accounting & Consulting Corp for a review before Labor Day. Primary sources: the IRS BBA Centralized Partnership Audit Regime page, Form 8985, Form 8986, and the PBBA e-submission portal.
