The Bipartisan Budget Act of 2015 created a new partnership audit regime that’s poised to take effect for tax years beginning after December 31, 2017. Under the new regime, the IRS is supposed to audit all partnerships. Partnerships can elect to have parts of the new regime apply before January 1, 2018. There are no exemptions for small partnerships. The IRS is seeking input on the new regime. Comments are requested by April 15, 2016.