Partnership merger tax rules under Sec. 708 showing two partnerships combining under the more-than-50% continuation test
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How Partnership Merger Tax Rules Work Under Sec. 708

BySW Accounting admin

How do partnership merger tax rules work under Sec. 708(b)(2)(A)? A resulting partnership is a continuation of any merging partnership whose partners own more than 50% of the capital and profits of the resulting partnership; other merging partnerships terminate. Consideration mixing cash and interests triggers disguised-sale analysis, and the merger cash-out rule at Regs. Sec….

Illustration of an IRS Form 8986 with a September 15 deadline calendar and a partnership tier flow chart
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BBA Partnership Audit 2026: Form 8986 Push-Out Deadline

BySW Accounting admin

When is the BBA partnership push-out deadline for a pass-through partner? If you received a Form 8986 tied to a partnership that filed an Administrative Adjustment Request (AAR) or was audited under the BBA partnership audit regime, the deadline to pay or push out further is generally September 15, 2026 — the exact date is…