After a shocking and unannounced repeal of the “small partnership” provision in late 2015, as part of the Bipartisan Budget Act of 2015,1 which was enacted as part of the Tax Equity and Fiscal Responsibility of 1982, the stunned users of that part of the 1982 Act began to raise questions. When does it go into effect? Will I end up with partnership status? Will I have a choice on what I can shift to? Will that shift be automatic or will it be an election? In the 27 months which have elapsed since enactment, not one word has emanated from the Internal Revenue Service. This article will, hopefully, focus on the problems and some of the likely options, but will certainly not be the last word on the issue.



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