This could allow investment partnerships, such as private equity funds and other alternative asset management funds, that already filed their 2018 tax return without an extension to potentially file superseding returns and re-issue Schedules K-1 to their investors. If a superseding return is filed within the extended filing due date provided for by this Revenue Procedure, it will replace the original return for all purposes. It allows such partnerships to make corrections to the originally filed partnership return - including the correction of missed elections that are required to be filed by the due date of the partnership return, with extension - and issue updated Schedules K-1. Revenue Procedure 2019-32 provides welcome relief for partnerships that are subject to the BBA rules and filed a timely 2018 tax year partnership return without extension. To apply the relief provided in Revenue Procedure 2019-32, eligible partnerships should file a superseding Form 1065 and furnish corresponding Schedules K-1 in the same manner as the original return and Schedules K-1 and write on the top of the superseding Form 1065 "SUPERSEDING FORM 1065 PURSUANT TO REVENUE PROCEDURE 2019-32." This relief applies only to partnership tax years that ended prior to the issuance of Revenue Procedure 2019-32 and for which the extended due date for such partnership tax year is after July 25, 2019. The eligible partnership must also file a superseding Form 1065 and furnish corresponding Schedules K-1 on or before the date that is six-months after the non-extended deadline. To be eligible for the relief, for the applicable tax year the partnership must have: (1) not made an election under IRC Section 6221(b), (2) timely filed Form 1065, and (3) timely furnished all required Schedules K-1. The superseding return would replace any prior return for the tax year for purposes of determining the partnership's treatment of partnership-related items under IRC Section 6222. As a result, BBA partnerships that timely filed a Form 1065 and timely furnished all required Schedules K-1 before the non-extended deadline may file a superseding Form 1065 and furnish corresponding Schedules K-1 before the expiration of the extended deadline. Under the relief provided in Revenue Procedure 2019-32, the IRS will treat the timely filing of Form 1065 by certain eligible BBA partnerships as a timely and appropriately filed request for a six-month extension of the deadline to file Form 1065. However, partnerships that timely filed for their 2018 tax year and did not request an extension (i.e., generally by March 15, 2019) would be prohibited under IRC Section 6031(b) - without the current relief - from amending their Schedules K-1 for the 2018 tax year in the event of errors on their already-filed Form 1065. Taxpayers that timely requested an extension may file original or superseding Forms 1065 and corresponding Schedules K-1 until Septem(the extended due date for the 2018 tax year). The IRS noted that tax years of partnerships beginning in 2018 were the first tax years for which the centralized partnership audit regime was mandatory and the first tax years for which restrictions on amending Schedules K-1 under IRC Section 6031(b) were effective. For calendar-year partnerships that timely request a six-month extension, the extended deadline is September 15. The deadline for partnerships to file Forms 1065 and furnish Schedules K-1, absent an extension, is the fifteenth day of the third month after the end of the partnership's tax year (i.e., March 15 for calendar-year partnerships). IRC Section 6031(b) generally prohibits BBA partnerships from amending the information required to be furnished to its partners after the due date of the return. IRC Section 6031(a) sets forth requirements for partnerships to file Form 1065 and furnish certain information to their partners on Schedules K-1. Under IRC Section 6222(a), partners in a BBA partnership must treat partnership-related items, as defined in IRC Section 6241, consistently on the partner's return with how the BBA partnership treated such items on its return. The centralized partnership audit regime enacted by the BBA applies to all partnerships, unless the partnership makes a valid election under IRC Section 6221(b) not to have those procedures apply. The Bipartisan Budget Act of 2015 (BBA) significantly altered the audit and income tax liability rules governing most partners and partnerships for tax years beginning after December 31, 2017. Return of Partnership Income, for tax year 2018, and provide corresponding Schedules K-1 to their partners. In Revenue Procedure 2019-32, the IRS has granted a six-month extension for certain eligible partnerships to file a superseding Form 1065, U.S. IRS gives eligible partnerships six-month extension to file superseding 2018 Forms 1065 and Schedules K-1