Instructions for Form 8082

Instructions for Form 8082

(Rev. October 2025)

Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)

Section references are to the Internal Revenue Code

unless otherwise noted.

Future Developments

For the latest information about developments related to

Form 8082 and its instructions, such as legislation

enacted after they were published, go to IRS.gov/

Form8082.

What’s New

Part I, line 1. The checkboxes for “AAR,” “TEFRA AAR,”

and “ELPs/REMICs” have been removed.

Part I, line 2. The checkbox for “TEFRA Partnership” has

been removed.

Part II. The heading for column (e) has been clarified.

General Instructions

Unless otherwise noted, references to sections 6221

through 6241 are to the Internal Revenue Code (the Code)

as amended by the Bipartisan Budget Act of 2015 (BBA)

and related regulations which describe processes and

procedures. They are referred to in these instructions as

“BBA proceedings.”

Purpose of Form

Notice of inconsistent treatment. If you’re a partner in

a BBA partnership, an S corporation shareholder, a

beneficiary of an estate or trust, an owner of a foreign

trust, or a residual interest holder in a real estate mortgage

investment conduit (REMIC), you must generally report

items consistent with the way they were reported by the

partnership to the IRS on Schedule K-1, Schedule K-3,

Form 8986 (issued with a BBA AAR), Schedule Q, and/or

a foreign trust statement. However, there may be reasons

why you wish to report these items differently. To do so,

use Form 8082 and the instructions under Inconsistent

Treatment, later.

Note: A partner is bound to finally determined

adjustments on Form 8986 resulting from a BBA

partnership audit and may not use Form 8082 to report the

items differently.

Use Form 8082 to notify the IRS of any inconsistency

between your tax treatment of an item and the way the

pass-through entity treated and reported the same item on

its return. Also use the form to notify the IRS if you didn’t

receive Schedule K-1, Schedule Q, and/or a foreign trust

statement from the foreign trust by the due date for filing

your return (including extensions). Additionally, based on

the instructions for Schedule K-2, if the pass-through

entity was required to provide a Schedule K-3 but didn’t,

use Form 8082 to notify the IRS of this.

Nov 21, 2025

AAR under BBA. Use Form 8082 if you’re the

partnership representative (PR) or designated individual

(DI) (if the PR is an entity) requesting an administrative

adjustment on behalf of the BBA partnership to correct a

previously filed partnership return. Go to IRS.gov/

BBAAAR for additional information. Also, see the

Instructions for Form 1065.

BBA created a new centralized partnership audit

regime generally effective for partnership tax years

beginning after 2017, replacing the consolidated audit

proceedings under sections 6221 through 6234 enacted

by TEFRA. All partnerships with tax years beginning after

2017 are subject to the centralized partnership audit

regime unless they make a valid election under section

6221(b). See section 6221(b) and the Instructions for

Form 1065 for information on which partnerships are

eligible to make this election.

For instructions on completing Form 8082 for this

purpose, see BBA AAR under Specific Instructions, later.

Definitions

AAR partnership. An AAR partnership is a BBA

partnership that has filed, or is filing, an AAR under

section 6227.

Adjustment year. For BBA partnerships, the adjustment

year is the partnership tax year in which:

• An adjustment pursuant to the decision of a court in a

proceeding brought under section 6234, such

decision becomes final;

• An AAR is filed under section 6227; or

• A notice of final partnership adjustment is mailed

under section 6231 or, if the partnership waives the

limitations on assessments under section 6232(b), the

waiver is executed by the IRS.

Audited partnership. For purposes of these instructions,

an audited partnership is a BBA partnership that made an

election under 6226 and issued Forms 8986 to its

partners. The partners of an audited BBA partnership are

bound by the adjustments and cannot file a Form 8082 to

treat the adjustments inconsistent with the results of the

audit.

BBA partnership. A partnership subject to the

centralized partnership audit regime is referred to as a

“BBA partnership.” All partnerships with tax years

beginning after 2017 are BBA partnerships unless, under

section 6221, they make a valid election out of the

centralized partnership audit regime. A partner in a BBA

partnership is referred to as a “BBA partner.” REMICs

subject to the centralized partnership audit regime are

also considered BBA partnerships for purposes of these

instructions. An AAR filed by a BBA partnership is referred

to as a “BBA AAR” and, if one is filed, it must be filed by

Instructions for Form 8082 (Rev. 10-2025) Catalog Number 62051N

Department of the Treasury Internal Revenue Service www.irs.gov

the PR or the DI if the PR is an entity. Go to IRS.gov/

BBAAAR for additional information.

Designated individual (DI). Where the PR is an entity,

the DI is the sole individual appointed by the partnership

at the time of the designation of the PR through whom the

entity PR acts.

Foreign trust statement. Any of the following annual

statements furnished by a foreign trust to its owners or

beneficiaries.

• Foreign Grantor Trust Owner Statement.

• Foreign Grantor Trust Beneficiary Statement.

• Foreign Nongrantor Trust Beneficiary Statement.

Form 8985, Pass-Through Statement—Transmittal/

Partnership Adjustment Tracking Report. Form 8985

is used by a BBA partnership to summarize and transmit

Forms 8986 (by an audited partnership, a partnership

filing an AAR, or a pass-through partner) in situations

where the partners are taking into account the

adjustments. Form 8985 is also used to report payments

made and related calculations by a pass-through partner

of a BBA partnership, if applicable. See the instructions for

these forms for further information.

Form 8986, Partner’s Share of Adjustment(s) to Partnership-Related Item(s). Form 8986 was created for

BBA partnerships and pass-through partners of BBA

partnerships to show each partner’s share of adjustments

to a PRI as a result of a BBA audit or BBA AAR for

situations where the partners are taking into account the

adjustments.

Imputed underpayment (IU). An IU is the amount a

partnership is potentially liable for as a result of an

adjustment to a partnership-related item (PRI). Whether

an adjustment results in an IU is determined in

accordance with the rules under Regulations section

301.6225-1, with that amount subject to possible

modification under Regulations section 301.6227-2.

Non-BBA partnership. Under BBA, certain partnerships

with 100 or fewer eligible partners for the tax year can

elect out of the centralized partnership audit regime. For

additional information, see the Instructions for Form 1065.

A partnership that elects out of the centralized partnership

audit regime is referred to as a “non-BBA partnership.”

Partnership-related item (PRI). For BBA partnerships,

under section 6241(2)(B), a PRI is any item or amount

with respect to the partnership that is relevant in

determining the income tax liability of any person, without

regard to whether the item or amount appears on the

partnership’s return. An item or amount is with respect to

the partnership if it is shown or reflected, or required to be

shown or reflected, on the partnership return or the forms

and instructions prescribed by the IRS for the

partnership’s tax year or is required under the Internal

Revenue laws to be maintained in the partnership’s books

or records. This includes an imputed underpayment (IU)

and an item or amount relating to any transaction with,

basis in, or liability of the partnership.

Partnership representative (PR). Under section 6223,

BBA partnerships must designate a partner or other

person with a substantial presence in the United States as

the PR who shall have the sole authority to act on behalf

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of the partnership. If the designated PR is an entity, the

partnership must also appoint a DI to act on behalf of the

entity PR. The appointed DI must be an individual and

may not be an entity. The partnership and all partners are

bound by the actions of the PR in dealings with the IRS

under BBA. Go to IRS.gov/BBAAAR for additional

information. A REMIC that’s a BBA partnership (hasn’t

elected out of BBA) would need to designate a PR.

Pass-through entity. A partnership, S corporation,

estate, trust, or REMIC.

Reporting year. Reporting year is applicable to partners

of BBA partnerships. It’s the partner’s tax year(s) that

includes the date the AAR partnership furnished Forms

8986 to its partners.

Reviewed year. For BBA partnerships, the reviewed year

is the partnership’s tax year to which a partnership

adjustment relates. For example, if the BBA AAR is filed to

make an adjustment to income for the 2023 tax year, 2023

is the reviewed year.

Reviewed year pass-through partner. For purposes of

these instructions, under BBA, a reviewed year

pass-through partner is a pass-through entity that held an

interest in a BBA partnership at any time during the

reviewed year, which is the partnership tax year to which

the partnership adjustment relates.

Schedule K-1. Schedule K-1 is an annual schedule

reporting the partner’s, shareholder’s, or beneficiary’s

share of income, deductions, credits, etc., from a

partnership, S corporation, estate, or domestic trust.

Schedule K-2. Schedule K-2 is an extension of Form

1065, Schedule K, used to report items of international tax

relevance from the operation of a partnership.

Schedule K-3. Schedule K-3 is an extension of

Schedule K-1 (Form 1065) generally used to report to

partners their shares of the items reported on

Schedule K-2.

Schedule Q. Schedule Q is a quarterly schedule

reporting the residual interest holder’s share of taxable

income or net loss from the REMIC.

Who Must File

Notice of inconsistent treatment. Generally, file Form

8082 if any of the following apply.

• You believe an item wasn’t properly reported on the

Schedule K-1 or Schedule K-3 you received from the

partnership, or on a Form 8986 (only issued with

respect to an AAR), S corporation, estate, or domestic

trust; the Schedule Q you received from the REMIC; or

the foreign trust statement you received from the

foreign trust.

• You believe an item shown on your schedule or

statement is incorrect but it isn’t an item that otherwise

has to be reported on your tax return. For example, if

you believe that the percentage shown as your

ownership of capital at the end of the year wasn’t

properly reported on Schedule K-1, file Form 8082 to

report this, even though you aren’t otherwise required

to report that percentage on your tax return. If you

discover this kind of inconsistency after filing your

Instructions for Form 8082 (Rev. 10-2025)

original return, file an amended return to report it. In

the space provided on the amended return for writing

explanations, enter “See attached Form 8082.” If the

correction doesn’t affect your tax return, no amounts

need to be entered on the amended return if the Form

8082 item is the only reason for filing the amended

return.

• The pass-through entity hasn’t filed a tax return or

given you a Schedule K-1, Schedule Q, or foreign trust

statement by the time you’re required to file your tax

return (including extensions) and there are items you

must include on your return.

• If the pass-through entity didn’t provide you

Schedule K-3 and it was required to do so according

to the instructions for Schedule K-2.

Caution: If you don’t notify the IRS that you’re reporting

an item (box (a) of Part I, line 1) inconsistently, any

deficiency (including any late filing or late payment

penalties applicable to the deficiency) that results from an

adjustment to make your amount or other treatment of the

item consistent with the amount or treatment of the item

on the pass-through entity’s return may be assessed

immediately. An inconsistent item can exist on either your

original or amended return.

AAR under BBA. File Form 8082 if you’re the PR or DI

requesting an administrative adjustment on behalf of the

BBA partnership to correct a previously filed partnership

return.

Tip: When a partnership’s federal return is changed for

any reason, it may affect its state return. For more

information, contact the state tax agency with which the

state return is filed.

Who May Not File

Don’t use Form 8082 to file a notice of inconsistent

treatment or an AAR if any of the following apply.

• If you’re a REMIC and want to correct items on the

original REMIC return. Instead, file Form 1065-X.

• For any amount of loss, deduction, or credit from

Schedule K-1, Schedule K-3, Schedule Q, Form 8986,

or the foreign trust statement that you don’t report on

your return because the amount is otherwise limited

by law (such as a loss limited by the at-risk or passive

activity rules).

• If you’re a partner in a partnership with a tax year

beginning after 2017 that has an election out of BBA in

effect pursuant to section 6221(b).

• If you’re a BBA partnership, you may not file an AAR

solely for the purpose of changing the PR. See the

Instructions for Form 8979, Partnership

Representative Designation or Resignation, for more

information.

• You may not file a BBA AAR after the prescribed time

to do so. If you’re a BBA partnership that has received

a notice of administrative proceeding, you may not file

an AAR (see How and When To File, later).

• If you’re a partner and the BBA partnership in which

you’re an investor has received a notice of

administrative proceeding, a Form 8082 with respect

to inconsistent treatment of partnership items from

that BBA partnership can’t be filed.

Instructions for Form 8082 (Rev. 10-2025)

• A partner may not file an AAR on behalf of the BBA

partnership in which it’s a partner unless doing so is in

its capacity as the PR for that partnership.

• If you’re a shareholder in an S corporation, except as a

notice of inconsistent treatment when the

shareholder’s return isn’t consistent with the return of

the S corporation. Form 8082 can’t be filed by a

shareholder to request an administrative adjustment to

their tax return to correct S corporation items. Instead,

the shareholder must file an amended income tax

return.

• If you’re a beneficiary of an estate or domestic trust, or

a beneficiary or an owner of a foreign trust, except as

a notice of inconsistent treatment when the

beneficiary’s or owner’s return isn’t consistent with the

return of the estate or trust. Form 8082 can’t be filed

by a beneficiary or owner to request an administrative

adjustment to their tax return to correct estate or trust

items. Instead, the beneficiary or owner must file an

amended income tax return.

• If you’re a residual interest holder and your REMIC

had no more than one residual interest holder at any

one time during the tax year.

• If you’re a residual interest holder in a REMIC with a

tax year beginning after 2017 that has an election out

of BBA in effect pursuant to section 6221(b).

Interest and Penalties

If you disregard the requirements for filing Form 8082, you

may be subject to the accuracy-related penalty under

section 6662 or the fraud penalty under section 6663.

Either penalty is in addition to any tax that results from a

computational adjustment to make your amount or

treatment of the item consistent with the amount or

treatment of the item on the pass-through entity’s return.

Interest. Generally, interest is charged on taxes not paid

by the due date, even if an extension of time to file is

granted. Interest is also charged on penalties imposed for

negligence, fraud, substantial valuation misstatements,

substantial understatements of tax, and reportable

transaction understatements. The interest is charged from

the due date (including extensions) to the date of

payment. The interest charge is figured at a rate

determined under section 6621.

Late payment penalty. The penalty for not paying the

tax when due is usually 1/2 of 1% of the unpaid tax for

each month or part of a month that the tax remains

unpaid. The penalty can’t exceed 25% of the unpaid tax.

Other penalties. Penalties can also be imposed for

negligence, substantial understatements of tax, reportable

transaction understatements, and fraud. See sections

6662, 6662A, and 6663.

Interest and penalties applicable to the IU. Except

when the partnership elects to have its partners take into

account the adjustments under section 6227(b)(2), BBA

partnership interest and penalties are the following.

• The interest figured for an IU is the interest that would

be determined under chapter 67 for the period

beginning on the day after the return due date for the

reviewed year and ending on the return due date for

the adjustment year as defined under section 6225(d)

(2) or, if earlier, the date the IU is paid.

3

• Any penalty, addition to tax, or additional amount that

is determined at the partnership level is applied as if

that BBA partnership had been an individual subject to

tax under chapter 1 for the reviewed year and the IU

were an actual underpayment (or understatement) for

that year for purposes of part II of subchapter A of

chapter 68.

Election to apply the alternative to payment of the IU.

If the partners must take into account the adjustments

because the BBA partnership filed an AAR and there are

adjustments that don’t result in an IU or if a BBA

partnership elects the alternative to payment of the IU

under sections 6227(b)(2) and 6226(c), interest shall be

determined:

• At the partner level;

• From the due date of the return for the tax year to

which the increase is attributable, determined by

taking into account any increases attributable to a

change in tax attributes for a tax year under section

6226(b)(2) until the date of payment; and

• At the section 6621(a)(2) underpayment rate.

How Many Forms To Complete

You must complete and file a separate form for each

pass-through entity for which you’re reporting an

inconsistent or AAR item. If you’re reporting more than

four inconsistent or AAR monetary items from one

pass-through entity, use additional Forms 8082 because

Part II only provides four lines (8 through 11). You don’t

need to complete lines 8 through 11 if not reporting a

change to the amount or treatment of a monetary item;

however, you must include an explanation of the

change(s) in Part III.

How and When To File

How to file. Don’t file Form 8082 by itself.

If you file Form 8082 as a notice of inconsistent

treatment, complete a single copy of the form, attach it to

your tax return, and file it when you file your original return.

Note: If you require more than the four lines provided in

Part II to report the inconsistent or AAR items, attach

additional Forms 8082 as necessary.

When to file. Generally, a pass-through entity may file an

AAR to change items on its return:

• Within 3 years after the later of:

1. The date on which the pass-through entity return

for that year is filed, or

2. The last day for filing the pass-through entity

return for that year (excluding extensions); or

• Before a notice of an administrative proceeding for the

tax year is mailed under section 6231.

Special rules. A partnership return or a REMIC return is

generally due by the 15th day of the 3rd month following

the close of the partnership’s or REMIC’s tax year. The tax

year of a REMIC always ends on December 31.

Special rules apply if the period of limitations has been

extended by agreement. See section 6235 and

Regulations section 301.6235-1 for details.

4

What To Attach

If applicable, attach the following items to Form 8082.

• If the corrected amount involves an item that must be

supported with a schedule, statement, or form, attach

the appropriate schedule, statement, or form. Include

the entity’s name and employer identification number

(EIN) on any attachments. See the Instructions for

Form 1065 for a list of forms that may be required.

Note: If the attachments needed to support the

corrected amount include copies of forms or

schedules from previously filed tax returns, enter at

the top of each previously filed form or schedule,

“Copy Only—Don’t Process.”

• A BBA partnership must attach a schedule to Form

8082 that supports the position(s) reported. If the

partnership doesn’t make an election under section

6227(b)(2) to have the adjustments taken into account

by the reviewed year partners and would like to modify

per section 6227(b)(1), it must attach a Form 8980,

Partnership Request for Modification of Imputed

Underpayments Under IRC Section 6225(c), that

supports any modifications made to the IU as

described in sections 6225(b) and 6225(c) and as

applied to a BBA AAR under section 6227(b)(1). See

Modifications to an Imputed Underpayment Included

in an Administrative Adjustment Request in Pub. 5346,

Instructions for Form 8980.

• Attach Forms 8985 and 8986, as applicable. Form

8986 is used by BBA partnerships to furnish and

transmit each partner’s share of adjustments to PRIs.

See the instructions for Forms 8985 and 8986 for

more information.

• If the AAR is a request for an electronically deposited

refund of $1 million or more, attach Form 8302,

Electronic Deposit of Tax Refund of $1 Million or More.

Specific Instructions

Specific instructions for most of the lines have been

provided. Lines that aren’t explained are self-explanatory.

Note: If the pass-through entity didn’t file a return or give

you a Schedule K-1, Schedule K-3 (and the pass-through

entity was required to provide one to you according to the

instructions for Schedule K-2), Schedule Q, and/or foreign

trust statement by the time you’re required to file your

return, complete Parts I and II to the best of your

knowledge.

Inconsistent Treatment

Name and Identifying Number

Enter the legal name of the entity and identifying number

on the appropriate lines.

Part I—General Information

Line 1

Check box (a) if you believe an item wasn’t properly

reported on Schedule K-1, Schedule K-3, Schedule Q,

Form 8986 (only issued with respect to an AAR), and/or

foreign trust statement you received, or if you haven’t

received a Schedule K-1, Schedule K-3 (that the

Instructions for Form 8082 (Rev. 10-2025)

pass-through entity was required to provide according to

the instructions for Schedule K-2), Schedule Q, or foreign

trust statement by the time you’re required to file your tax

return (including extensions). Go to line 2.

Lines 2 Through 6

Generally, the information for these lines can be found on

Schedule K-1, Form 8986, Schedule Q, or the foreign trust

statement.

Line 6. Tax year of pass-through entity. If you’re a

partner filing a notice of inconsistent treatment from a

Form 8986 received as a result of a BBA partnership AAR,

enter the pass-through entity tax year that includes the

date contained in box D of Form 8986, Part II.

Part II—Inconsistent or Administrative

Adjustment Request (AAR) Items

Partner filing a notice of inconsistent treatment for a

Schedule K-1 or Schedule K-3 received from a BBA

partnership. When a partner receives a Schedule K-1 or

Schedule K-3 from a BBA partnership, it must generally

file consistently with that Schedule K-1 or Schedule K-3.

However, a partner may file inconsistently if it provides

valid notice to the IRS of inconsistent treatment.

Notice of inconsistent treatment filed with return. If

a pass-through partner doesn’t receive a Schedule K-1 or

Schedule K-3 (and the pass-through entity was required to

provide one according to the instructions for

Schedule K-2) from a BBA partnership or does receive a

Schedule K-1 or Schedule K-3 but disagrees with some or

all of the reported treatment or amounts, it may file a

notice of inconsistent treatment with its return (original or

amended/AAR). To do so, as a pass-through partner,

you’ll include Form 8082 with your return (for example,

Form 1065, Form 1120-S), prepare your return using the

treatment or amounts you determine are correct, and do

the following.

1. On Form 8082, check box (a) under Part I, line 1 (and

box (b), if applicable).

2. See Lines 8 Through 11—Inconsistent Treatment,

later, for how to complete columns (a) through (e) of

Part II.

3. File Form 8082 along with the applicable return and

attach any other supporting documents required.

Other than pass-through partner filing a notice of inconsistent treatment from a BBA partnership. If

you’re a partner (other than a pass-through partner) filing

inconsistently from a BBA partnership (that is,

inconsistently from a Schedule K-1, Schedule K-3, and/or

Form 8986 you received as a result of a BBA partnership

filling an AAR, and not as a result of an audit), complete

Form 8082 and attach it to your original or amended

return. If filing inconsistently from a Form 8986 (received

as a result of a BBA partnership filing an AAR and not as a

result of an audit), attach Form 8082 to your reporting year

return that corresponds to the Form 8986 received. Attach

a copy of the Form 8986 received from which you’re filing

inconsistently. See Reporting year, earlier. See Lines 8

Instructions for Form 8082 (Rev. 10-2025)

Through 11—Inconsistent Treatment below for how to

complete Part II, columns (a) through (e).

Lines 8 Through 11—Inconsistent Treatment

Note: Lines 8 through 11 are only required if reporting a

change to the amount or treatment of a monetary number.

Column (a). If you received a Schedule K-1,

Schedule K-3, Schedule Q, Form 8986 (as a result of a

BBA AAR and not as a result of an audit), and/or foreign

trust statement, enter the line number and description

shown on the form. For example, if you’re a BBA partner

providing notice of inconsistent treatment for a Form 8986

received (as a result of a BBA AAR and not as a result of

an audit), enter the information from the first three

columns of Form 8986, Part V, that you’re treating

inconsistently. Otherwise, enter a complete description of

the item.

If you didn’t receive a Schedule K-1, Schedule K-3,

Schedule Q, and/or foreign trust statement but are still

reporting estimated amounts on your original filing, enter a

complete description of the item and where you’re

reporting the estimated amount on your original return.

Column (b). If you believe that the amount of any item

shown on Schedule K-1, Schedule K-3, Schedule Q, Form

8986 (as a result of a BBA AAR and not as a result of an

audit), and/or a foreign trust statement wasn’t properly

reported, check the box under “Amount of item.”

If you believe that treatment of any item (other than the

amount of the item) wasn’t properly reported (such as a

long-term capital loss that a partner thinks should be an

ordinary loss), check the box under “Treatment of item.”

Check both parts of column (b) if either (1) or (2) below

applies.

1. You believe that both the amount and another

treatment (besides the amount) of the item shown on

Schedule K-1, Schedule K-3, Schedule Q, Form 8986

(as a result of a BBA AAR and not as a result of an

audit), and/or a foreign trust statement weren’t

properly reported, or you believe an item was omitted

from the form.

2. The pass-through entity didn’t file a return or give you

a Schedule K-1, Schedule K-3 (and the pass-through

entity was required to provide one to you according to

the instructions for Schedule K-2), Schedule Q,

and/or foreign trust statement.

Note: If you check only “Treatment of item,” you don’t

need to complete columns (d) and (e).

Column (c). If you attach Form 8082 to your return, to

make a notice of inconsistent treatment, enter the amount

as shown on the Schedule K-1, Schedule K-3,

Schedule Q, Form 8986 (as a result of a BBA AAR and

not as a result of an audit), and/or foreign trust statement

you received.

If the pass-through entity didn’t file a return, or if you

didn’t receive a schedule or statement, or if you’re

reporting items that you believe were omitted, enter zero

in column (c).

5

Forms 8985 and 8986. BBA partnerships filing an AAR

must furnish a Form 8986 to each reviewed year partner if:

• It makes an election under section 6227(b) to have the

adjustments taken into account by the reviewed year

partners,

• The adjustments result in an IU of zero or less than

zero, or

• The adjustments don’t result in an IU.

Caution: Use Form 8986 to notify partners of their

allocable shares of adjustments, don’t use an amended

Schedule K-1.

Form 8986 reflects a partner’s share of an adjustment

to a PRI. Form 8985 summarizes the information reported

on the Forms 8986. Forms 8985 and 8986 are required to

be filed with the AAR.

Inconsistent treatment of Form 8986. If you receive

Form 8986 as a result of a BBA AAR (and not as a result

of an audit), attach Form 8082 to the copy of the return (or

amended return) you file. Report the following inconsistent

amounts from the applicable “Corrected” column of Form

8986 in column (c) of Form 8082, Part II.

• Liabilities or capital items in Form 8986, Part IV.

• Item of income, gain, loss, deduction, or credits in

Form 8986, Part V.

• Any other items in Form 8986, Part VI.

Column (d). Enter the amount you’re reporting as the

correct amount in column (d).

Column (e). Enter the net increase or decrease for each

line being changed in column (e). Enter as a positive the

amount by which column (d) exceeds column (c) or enter

as a negative the amount by which column (c) exceeds

column (d). Use parentheses around all amounts that are

negative. Explain the reason for the change (increase or

decrease) in Part III.

Part III—Explanations

Explain in detail the reasons you’re reporting an

inconsistent or corrected amount or item as follows.

• If you believe that the amount or other type of

treatment of any item shown on Schedule K-1,

Schedule K-3, Schedule Q, Form 8986 (as a result of

a BBA AAR and not as a result of an audit), and/or a

foreign trust statement wasn’t properly reported, state

how you think the item should be treated and why.

• If the pass-through entity hasn’t filed a tax return by

the time you’re required to file your tax return, enter as

the explanation, “Partnership (S corporation, Estate,

Trust, or REMIC) return not filed.”

• If the pass-through entity didn’t give you a

Schedule K-1, Schedule K-3 (and the pass-through

entity was required to provide one to you according to

the instructions for Schedule K-2), Schedule Q, and/or

foreign trust statement by the time you’re required to

file your tax return, enter as the explanation,

“Schedule K-1 (Schedule K-3, Schedule Q, and/or

foreign trust statement) not received.”

6

BBA AAR

Name and Identifying Number

Enter the legal name of the entity and identifying number

on the appropriate lines.

Part I—General Information

Line 1

Check box (b) if you’re filing an AAR on which you’re

requesting a change in the amount or treatment of any

item from the way you reported it on your return as

originally filed or as you later amended it. Subject to the

particular filing rules, an AAR can be filed by partnerships

subject to BBA proceedings (BBA AAR). An AAR can also

be filed by the partnership-partners in a BBA partnership

(but only for the purpose of providing notice of

inconsistent treatment with the AAR). See Regulations

section 301.6227-1(a) referring to Regulations section

301.6222-1.

For Partnership Tax Years Beginning After 2017

BBA AAR. All partnerships with tax years beginning after

2017 are subject to the centralized partnership audit

regime unless an eligible partnership makes a valid

election under section 6221(b) to elect out of the

centralized partnership audit regime.

Partnerships that are subject to the centralized

partnership audit procedures of sections 6221 through

6241 are referred to as “BBA partnerships.” A partnership

with a tax year beginning after 2017 that isn’t subject to

BBA proceedings because it has made a valid election

under section 6221(b) is referred to as a “non-BBA

partnership.” An AAR filed by a BBA partnership is a BBA

AAR.

Caution: If a BBA partnership files an AAR and it needs

to make its partners aware of their allocable shares of

adjustments, it will furnish to each partner for the reviewed

year a Form 8986 reflecting the partner’s share of the

adjustments (and shouldn’t provide amended Schedules

K-1 or K-3). The partnership is also required to file with the

AAR any Forms 8986 required to be furnished to partners

along with Form 8985. See the instructions for these forms

for further information.

The partnership will need to furnish Forms 8986 to

make its partners aware of their allocable shares of

adjustments when (a) the adjustments in the BBA AAR

result in an IU of zero or less than zero, or the adjustments

don’t result in an IU; or (b) the adjustments in the BBA

AAR do result in an IU greater than zero but (as an

alternative to payment) the BBA partnership makes a valid

election under section 6227(b)(2) to have each reviewed

year partner take its share of adjustments into account.

See items B, C1, C2, and D that follow.

Item A. If “Yes” is checked, complete Form 8979 and

attach it to the AAR. See the Instructions for Form 8979.

Item B. BBA partnerships filing an AAR will need to

determine if the partnership adjustments result in an IU.

See Figuring the IU, later, for information on how to figure

the IU. The BBA partnership should consider all available

Instructions for Form 8082 (Rev. 10-2025)

guidance issued by the IRS in making a determination of

whether or not the AAR results in an IU. Also, see IU

Under the Centralized Partnership Audit Regime, later, for

discussion of the IU.

Note: An IU calculation must always be made and

presented on the AAR. This even applies when the IU is

zero or less than zero, or the adjustments don’t result in an

IU. See Figuring the IU, later, under Part III for more

information.

Item C1. If the adjustments contained in the BBA AAR

result in an IU, the partnership must pay the IU at the

same time the AAR is filed. However, under section

6227(b)(2), the partnership can elect to have its reviewed

year partners take the adjustments into account. This is an

election to push out the adjustments to the partners as an

alternative to payment of the IU. See section 6226(a)(2)

for details. If this valid election is made, the partnership is

no longer liable for the IU.

Caution: If the partnership’s election under 6227(b)(2) to

push out the adjustments to the partners is determined to

be invalid, the partnership will still remain liable for the IU.

Item C2. The partnership will need to furnish a Form

8986 to each reviewed year partner reflecting the partner’s

share of adjustments for when the adjustments don’t

result in an IU (for example, the adjustments in the BBA

AAR result in an IU of zero or less than zero; or there is a

net negative adjustment).

The partnership is also required to file with the AAR all

Forms 8986 furnished to partners and Form 8985. See the

instructions for these forms for further information.

Note: The BBA partnership doesn’t furnish Schedules

K-1 to its partners when filing a BBA AAR. Instead, it will

provide Forms 8986.

Note: A partnership that makes an election under section

6227(b)(2) to push out adjustments to its partners must

nevertheless pay any taxes, penalties, additions to tax,

additional amounts, or the amount of any adjustments to

any IU previously reported by the partnership (for

example, when correcting an IU previously reported on an

AAR) for which the partnership is liable under chapter 1 of

the Code or the BBA (subchapter C of chapter 63) at the

time the partnership furnishes statements to its partners.

Any adjustments to such items aren’t included in the

statements the partnership furnishes to its partners and

files with the IRS. These items aren’t allocable to partners;

rather, they are entity-level liabilities of the partnership and

should not be pushed out to partners but paid by the

partnership.

Item D. Each reviewed year partner is required to take

into account its share of adjustments requested in a BBA

AAR if the partnership adjustments result in a positive IU

and the partnership makes the alternative to payment

election discussed under Item C1, earlier. Additionally,

each reviewed year partner is required to take into

account its share of any adjustments requested in a BBA

AAR resulting in an IU of zero or less than zero, or that

don’t result in an IU. The determination of whether or not

an adjustment results in an IU amount is discussed earlier

under Item B.

Instructions for Form 8082 (Rev. 10-2025)

The partnership is required to furnish each reviewed

year partner with a Form 8986 reporting its share of the

BBA AAR adjustments. The PR (or DI if the PR is an

entity) must attest to the partnership’s compliance with

this requirement. The PR will manually sign Form 8082

under item D to declare under penalties of perjury that all

statements have been provided to the reviewed year

partners as required by these instructions. Form 8082

should be attached as a PDF to Form 1065.

Item E. Under section 6227(b)(1), the partnership may

modify the IU resulting from adjustments reported in a

BBA AAR in accordance with the provisions under section

6225(c), disregarding the provisions under paragraphs

(2), (7), and (9). Any modification made to the IU under

section 6227(b)(1) must be disclosed and fully explained

on Form 8980 included with the AAR.

Note: If the partnership makes a valid election to push out

the adjustments to the partners as alternative to payment

of the IU, any modifications applied to the IU are

disregarded.

Caution: If the partnership makes an election to push out

the adjustments rather than pay an IU but the election is

determined to be invalid, the partnership remains liable for

the IU and such IU may potentially be assessed. In such a

case where the partnership filed Form 8980 to request

permitted modifications be applied to the IU calculation,

those modifications will be considered in determining the

IU.

Part II—Inconsistent or Administrative

Adjustment Request (AAR) Items

If a BBA partnership is filing an AAR to change items that

were reported on its original return, do the following.

1. Determine the required changes to be made.

2. Complete Form 8082 to identify the changes being

made.

a. On Form 8082, check box (b) under Part I,

line 1.

b. See Lines 8 Through 11—BBA AAR, later, for

how to complete columns (a) through (e) of Part II.

3. Figure an IU and determine if there are any

adjustments that don’t result in an IU. If there are

adjustments that don't result in an IU, complete Forms

8985 and 8986.

4. Determine if it will pay the IU or push out the

adjustments to the partners.

a. If any modifications are applied to the IU,

include a completed Form 8980 with the filing of

the AAR.

b. If pushing out the adjustments to the reviewed

year partners, complete Form 1065 (see

Administrative Adjustment Request (AAR) in the

Instructions for Form 1065). Also complete Forms

8985 and 8986.

Caution: Schedules K-1 shouldn't be included

with the AAR. Any information required to be

reported is done so on Form 8986 instead of

being reported on Schedules K-1.

7

Note: See Caution, earlier.

5. File Form 8082 along with Form 1065, and attach any

other supporting documents required, including

copies of Forms 8985 and 8986 (if applicable).

6. If applicable, distribute the Forms 8986 to reviewed

year partners according to the Form 8986

instructions.

Subject to the particular filing rules, an AAR can be filed

by partnerships subject to BBA proceedings (BBA AAR).

Lines 8 Through 11—BBA AAR

Note: Lines 8 through 11 are only required if reporting a

change to the amount or treatment of a monetary number.

Column (a). Enter the line number and description from

the form for which you’re making the change. For example,

if you’re changing the amount reported on Schedule K,

line 1, enter “Schedule K, line 1.”

Column (b). Check the box under “Amount of item” if

you’re changing the amount from what was previously

filed. Check the box under “Treatment of item” if you’re

reporting the amount unchanged but are changing

another treatment of the item. Check both boxes if you’re

changing the amount and another treatment besides the

amount.

Column (c). Report the amount you previously reported

for the item listed in column (a).

Column (d). Enter the amount you’re reporting as the

correct amount in column (d).

Column (e). Enter the net increase or decrease for each

line being changed in column (e). Enter as a positive the

amount by which column (d) exceeds column (c), or enter

as a negative the amount by which column (c) exceeds

column (d). Use parentheses around all amounts that are

negative. Explain the reason for the change (increase or

decrease) in Part III.

Part III—Explanations

Explain in detail the reasons you’re reporting an

inconsistent or corrected amount or item as follows.

• If the pass-through entity hasn’t filed a tax return by

the time you’re required to file your tax return, enter as

the explanation, “Partnership (S corporation, Estate,

Trust, or REMIC) return not filed.”

• If the pass-through entity didn’t give you a

Schedule K-1, Schedule K-3 (and the pass-through

entity was required to provide one to you according to

the instructions for Schedule K-2), Schedule Q, and/or

foreign trust statement by the time you’re required to

file your tax return, enter as the explanation,

“Schedule K-1 (Schedule K-3, Schedule Q, and/or

foreign trust statement) not received.”

IU Under the Centralized Partnership Audit

Regime

BBA AARs must always include a computation of the IU

(even when the IU is zero or less than zero, or the

adjustments don’t result in an IU), as determined under

section 6225(b). See Figuring the IU, later, for information

on how to figure the IU. Also, go to IRS.gov/Businesses/

8

Partnerships/How-To-Figure-an-Imputed-Underpayment.

Documentation should be included with the AAR that

supports the computation of the IU amount. The BBA

partnership should consider all available guidance issued

by the IRS when figuring the IU amount for an AAR. If the

calculated IU amount results in an amount greater than

zero and the partnership doesn’t elect under section

6227(b)(2) to have its reviewed year partners take the

adjustments into account, the partnership must report and

pay the IU and any interest and penalty associated with

the IU at the time the AAR is submitted. See Interest and

penalties applicable to the IU, earlier.

If the adjustments requested in the AAR result in an IU,

generally the partnership must pay the IU. Adjustments

requested in the AAR that don’t result in an IU must be

taken into account by each reviewed year partner as if the

partnership had made an election under section 6227(b)

(2) but only with regard to those adjustments that don’t

result in an IU. In this instance, see Forms 8985 and 8986

and the related instructions for reporting amounts not

included in the IU.

The partnership may elect under section 6227(b)(2) to

have the reviewed year partners take into account

adjustments resulting in an IU. If the partnership makes

the election, the partnership isn’t liable for, nor required to

pay, the IU related to the adjustments. Additionally, if the

IU calculation results in an amount that is zero or less than

zero, or the adjustments don’t result in an IU, then all

adjustments are taken into account by the reviewed year

partners. However, the partnership may have withholding

and reporting obligations under chapter 3 or 4 with

respect to the adjustments taken into account by the

reviewed year foreign partners. See Forms 8985 and 8986

and their related instructions for how to report these

adjustments to reviewed year partners.

Note: A partnership that makes an election under

6227(b)(2) to have the reviewed year partners take into

account adjustments resulting in an IU won’t push out any

taxes, penalties, additions to tax, additional amounts, or

the amount of any adjustments to any IU previously

reported by the partnership (for example, when correcting

an IU previously reported on an AAR) for which the

partnership is liable under chapter 1 of the Code or the

BBA (subchapter C of chapter 63). Instead, the

partnership must pay any of these amounts for which the

partnership is liable at the time the partnership furnishes

statements to its partners.

If the partnership validly elects under section 6227(b)

(2) to have its reviewed year partners take all the

adjustments into account, any modifications applied to the

IU submitted on Form 8980 will be disregarded.

Under section 6227(b)(1), the partnership may modify

the IU in accordance with the provisions under section

6225(c), disregarding the provisions under sections

6225(c)(2), (7), and (9). If modifications are applied to the

IU, complete and attach Form 8980 and report the

modified IU amount on Form 1065, page 1, line 26.

Note: Regarding modifications, see Item E under Part I,

earlier.

Instructions for Form 8082 (Rev. 10-2025)

Caution: If the partnership makes an election to push out

the adjustments rather than pay an IU but the election is

determined to be invalid, the partnership remains liable for

the IU and such IU may potentially be assessed. In such a

case where the partnership filed Form 8980 to request

permitted modifications be applied to the IU calculation,

those modifications will be considered in determining the

IU.

The applicability of interest and penalties is discussed

under Interest and penalties applicable to the IU, earlier.

The BBA AAR may include a prepayment for interest and

penalties. If making prepayments, the AAR should include

documentation that supports the calculations. A schedule

must be attached to Form 1065 that details the portions of

the prepayment that are for the IU, the prepaid estimated

interest, and the prepaid estimated penalties. The total of

all three should be reflected on Form 1065, page 1,

line 26.

Details of the IU Reported on Form 1065, Page 1, Line 26

Description

Amount

1. IU amount . . . . . . . . . . . . . . . . . . . . . .

2. Estimated interest

. . . . . . . . . . . . . . . . .

3. Estimated penalties* . . . . . . . . . . . . . . . .

4. Total payment (sum of lines 1 through 3)

. . .

* Include an explanation of the penalties associated with the estimated

payment.

Under section 6232(a)(2), partnerships filing a BBA

AAR that have adjustments resulting in an IU, and that

don’t elect the alternative to payment of the IU, must pay

the IU at the time of filing the AAR. The IU should be

shown on Form 1065, page 1, line 26. When paying by

check, include the name of the partnership, “Form 1065,”

the taxpayer identification number of the partnership, the

tax year, and “BBA AAR Imputed Underpayment.” Checks

must be made payable to “United States Treasury” and

included with the BBA AAR. If making an electronic

payment, choose the payment description “BBA AAR

Imputed Underpayment” from the list of payment types.

Figuring the IU

Definitions

Adjustments not resulting in an IU. After grouping,

subgrouping, and netting the adjustments, the result of

netting with respect to any grouping or subgrouping that

includes a particular partnership adjustment is a net

negative adjustment or the IU calculation results in an

amount that is zero or less than zero. Any adjustments that

don’t result in an IU are taken into account by the reviewed

year partners in accordance with Regulations section

301.6227-3.

Credit grouping. Any adjustment to a PRI that is

reported or could be reported by a partnership as a credit

on the partnership’s return, including a reallocation

adjustment to such PRI, is placed in the credit grouping.

Creditable expenditure grouping. Any adjustment to a

PRI where any person could take the item that is adjusted

(or item as adjusted if the item wasn’t originally reported

Instructions for Form 8082 (Rev. 10-2025)

by the partnership) as a credit, including a reallocation

adjustment to a creditable expenditure, is placed in the

creditable expenditure grouping.

Negative adjustment. A negative adjustment is any

adjustment that is a decrease in an item of gain or income;

an increase in an item of loss or deduction; an increase in

an item of credit or creditable expenditure; a decrease in

an item of tax, penalty, addition to tax, or additional

amount for which the partnership is liable under chapter 1;

or a decrease to an IU calculated by the partnership for

the tax year.

Net negative adjustment. Any amount which results

from netting adjustments within a grouping or subgrouping

that isn’t a net positive adjustment. A net negative

adjustment includes a negative adjustment that wasn’t

netted with any other adjustment.

Net positive adjustment. An amount that is greater than

zero which results from netting adjustments within a

grouping or subgrouping. A net positive adjustment

includes a positive adjustment that wasn’t netted with any

other adjustment. A net positive adjustment includes a net

decrease in an item of credit (or creditable expenditure).

Positive adjustment. A positive adjustment is any

adjustment that isn’t a negative adjustment.

Reallocation grouping. In general, any adjustment that

allocates or reallocates a PRI to and from a partner or

partners is a reallocation adjustment, except for an

adjustment to a credit or to a creditable expenditure. Each

reallocation adjustment generally results in at least two

separate adjustments, each of which becomes a separate

subgrouping.

Residual grouping. Any adjustment to a PRI that

doesn’t belong in the reallocation, credit, or creditable

expenditure grouping is placed in the residual grouping.

This grouping also includes any adjustment to a PRI that

derives from an item that wouldn’t have been required to

be allocated by the partnership to a partner under section

704(b), such as an adjustment to a liability amount on the

balance sheet.

Subgrouping. Each adjustment is subgrouped

according to how the adjustment would be required to be

taken into account separately under section 702(a). In

general, a subgrouping follows Schedules K, K-1, K-2,

and K-3 line items, including any alpha codes related to a

Schedule K-1, K-2, or K-3 line item.

Total netted partnership adjustments (TNPA). The

sum of all net positive adjustments in the reallocation

grouping and the residual grouping.

Formula for Figuring the IU

Figuring the IU

TNPA x rate* =

+ Sum of net positive adjustments

to creditable expenditure and

credit groupings:

= Total IU

* Highest rate in effect for the reviewed year under section 1 or 11.

9

The process of taking the adjustments shown on the

AAR and inputting them into the formula shown in the

previous table requires an understanding of the concepts

of grouping, subgrouping, and netting. There are seven

steps necessary in figuring an IU. The first three steps

focus on grouping, subgrouping, and netting.

Steps in Figuring the IU

Step 1—Grouping

Place each adjustment into one of the following four

groupings: reallocation, credit, creditable expenditure, or

residual grouping.

Note: Under Regulations section 301.6225-1(b)(4), solely

for purposes of calculating any IU, a partnership that files

an AAR may treat a positive adjustment as zero if the

positive adjustment is related to, or results from, a positive

adjustment to another item. The IRS may determine that

the adjustment should not have been treated as zero by

the partnership in its calculation of the IU. Go to IRS.gov/

Businesses/Partnerships/How-To-Figure-an-ImputedUnderpayment.

Reallocation grouping. A reallocation adjustment

generally consists of at least two adjustments, one

positive and one negative, with each in a separate

subgrouping.

• One part of the reallocation adjustment reverses the

effect of the improper allocation of a PRI.

• The other part of the adjustment makes the proper

allocation of the PRI.

• Under Regulations section 301.6227-2(d), if one of the

reallocation adjustments is negative, such negative

adjustments must be pushed out to the proper

partner(s).

Caution: Don’t net reallocation adjustments. As each part

of a reallocation adjustment is placed in a separate

subgrouping within the reallocation grouping, those

adjustments can’t be netted in accordance with the netting

rules.

Example. $100 of ordinary income is being

reallocated from Partner A to Partner B. For purposes of

figuring the IU, there will be two adjustments, each in a

separate subgrouping: a negative adjustment of $100

(reversing improper allocation to Partner A) and a positive

adjustment of $100 (making proper allocation to Partner

B). These two adjustments can’t be netted. As a result, the

total net positive adjustment in the reallocation grouping is

$100 and will be included in the TNPA. The net negative

adjustment of $100 is an adjustment that doesn’t result in

an IU and will be pushed out to the proper partner(s).

Credit grouping.

• Generally, a decrease in credits is treated as a positive

adjustment, and an increase in credits is treated as a

negative adjustment.

• A reallocation adjustment relating to the credit

grouping is placed into two separate subgroupings

and won’t be netted together nor will they be netted

with other credit adjustments.

10

Note: A change made to a previously reported IU (for

example, an IU reported on a prior AAR by the

partnership) is placed in the credit grouping and isn’t

permitted to be pushed out to the partners, as it is a

liability of the partnership.

Creditable expenditure grouping.

• Generally, a decrease in creditable expenditures is

treated as a positive adjustment, and an increase in

creditable expenditures is treated as a negative

adjustment.

• A reallocation adjustment relating to a creditable

expenditure grouping is placed into two separate

subgroupings and won’t be netted together.

• A creditable expenditure is treated in this manner even

if the partners claimed a deduction in lieu of a credit.

• Each adjustment to a creditable expenditure is

subgrouped based upon the separate category of

income to which the creditable expenditure relates

and to account for any different allocation of the

creditable expenditure between partners. Two or more

adjustments to creditable expenditures are included

within the same subgrouping only if each adjustment

relates to creditable expenditures in the same

separate category, and each adjusted PRI would be

allocated to the partners in the same ratio had those

items been properly reflected on the originally filed

partnership return.

Residual grouping. The residual grouping contains all

adjustments that don’t fit into one of the other groups.

Recharacterization adjustments. A recharacterization

adjustment may result in two separate adjustments within

the residual grouping.

• One adjustment reverses the improper

characterization of the PRI.

• The other adjustment makes the proper

characterization of the PRI.

• The adjustments that result from a recharacterization

are placed into separate subgroupings.

Step 2—Subgrouping

Determine if any adjustment, within one of the four

groupings, needs to be subgrouped. Subgrouping is

generally required within a grouping if there’s a negative

partnership adjustment within that grouping. Each

adjustment is subgrouped according to how the

adjustment would be required to be taken into account

separately under section 702(a). If any adjustment could

be subject to any preference, limitation, or restriction

under the Code (or not allowed, in whole or in part,

against ordinary income) if taken into account by any

person, the adjustment is placed in a separate

subgrouping from all other adjustments within the

grouping.

Generally, each separate line item of Schedules K, K-1,

K-2, and K-3 or return schedule (that is, Schedule L, etc.)

represents a separate and distinct subgrouping.

Example. Adjustments to ordinary income must be

placed in a different subgrouping than capital gain income

Instructions for Form 8082 (Rev. 10-2025)

or interest income because each of those items is

required to be separately stated under section 702(a).

• Subgroupings generally reflect a line item from

Schedules K, K-1, K-2, and K-3 including any

subcategories of those lines (for example, alpha

codes per the Schedule K-1 instructions or activities

broken out via attached statements). If any line item

on Schedules K or K-1 or other schedules consists of

multiple items and the components are required to be

taken into account separately under the Code,

regulations, forms, instructions, or other IRS guidance,

then such line item must be further subgrouped.

Example. Box 13, code A (cash contributions

60%); and box 13, code B (cash contributions 30%),

of 2019 Schedule K-1 are two separate subgroupings.

• The ordinary income (loss) amount reported on

Schedule K, line 1, and in box 1 of Schedule K-1 is

sourced from Form 1065, page 1, and is a net amount

consisting of various page 1 line items of income and

expenses. Although those separate page 1 line items

are distinct items of income and expense, if they are

appropriately netted and included on Schedule K,

line 1, and in box 1 of Schedule K-1, the net amount

will be considered a single subgrouping, except when

such amount is required to be separately allocated,

such as when the partnership has more than one

trade or business. If the partnership has more than

one trade or business activity, the net income (loss)

from each separate activity must be reported on

Schedule K-1. Each separate activity will constitute a

separate subgrouping and it must be determined

which activity an adjustment to the page 1 item of

income and expense relates to for subgrouping

purposes.

• If you have a negative adjustment along with a positive

adjustment in the same line item of Schedules K and

K-1, you must consider whether they may be properly

netted at the partnership level and whether they are

required to be taken into account separately by any

partner. They may be subject to a limitation or

preference under the Code before you can place them

in the same subgrouping (for example, passive and

nonpassive activities).

• A negative adjustment that isn’t otherwise required to

be placed in its own subgrouping must be placed in

the same subgrouping as another adjustment if the

negative adjustment and the other adjustment would

have been properly netted at the partnership level and

such netted amount would have been required to be

allocated to the partners of the partnership as a single

item for purposes of section 702(a) or other provision

of the Code and regulations.

Step 3—Netting

Net all adjustments within each of the groupings and

subgroupings.

• Positive adjustments may be netted with other positive

adjustments only if they are in the same grouping.

• Negative adjustments may be netted with other

negative adjustments only if they are in the same

subgrouping.

Instructions for Form 8082 (Rev. 10-2025)

• Positive and negative adjustments may only be netted

against each other if they are in the same

subgrouping.

• An adjustment in one grouping or subgrouping may

not be netted against an adjustment in any other

grouping or subgrouping.

• All adjustments within a subgrouping are netted to

determine whether there is a net positive adjustment

or net negative adjustment for that subgrouping.

• Net positive adjustments from subgroupings or

positive adjustments within a grouping (if

subgroupings are unnecessary) are netted to

determine the net positive adjustment for that

grouping. Net negative adjustments from

subgroupings within a grouping are netted to

determine the net negative adjustment for that

grouping.

Step 4—Figure the Total Netted Partnership

Adjustments (TNPA)

• Each net positive adjustment with respect to a

particular grouping or subgrouping in the residual or

reallocation grouping that results after netting the

adjustments is included in the calculation of the TNPA.

• Each net negative adjustment with respect to a

residual or reallocation grouping or subgrouping that

results after netting the adjustments is excluded from

the calculation of the TNPA because those

adjustments don’t result in an IU.

Note: Under Regulations section 301.6225-1(b)(4), a

partnership that files an AAR may treat a positive

adjustment as zero (solely for purposes of calculating any

IU) if the positive adjustment is related to, or results from,

a positive adjustment to another item. The IRS may later

determine that the adjustment should not have been

treated as zero by the partnership in its calculation of the

IU. Go to IRS.gov/Businesses/Partnerships/How-ToFigure-an-Imputed-Underpayment.

Step 5—Determine the Highest Tax Rate in Effect

Under Section 1 or 11 in the Reviewed Year

Step 6—Determine the Sum of Net Positive

Adjustments to Creditable Expenditures and

Credit Groupings That Will Increase the Product of

the TNPA Multiplied by the Highest Rate in Effect

• A net decrease to creditable expenditures is treated

as a net positive adjustment and increases the

product of the TNPA multiplied by the highest tax rate

in effect. A net increase to creditable expenditures is

treated as a net negative adjustment (including net

negative adjustments resulting from a creditable

expenditures reallocation adjustment) that’s excluded

from the calculation of the TNPA and is an adjustment

that doesn’t result in an IU.

• For the credit grouping, a net positive adjustment will

increase the product of the TNPA multiplied by the

highest tax rate in effect. A net negative adjustment,

including net negative adjustments resulting from a

11

credit reallocation adjustment, will be treated as an

adjustment that doesn’t result in an IU.

Step 7—Figure the IU Based on the Results of

Steps 4 Through 6 and Insert Those Results Into

the IU Formula

Figuring the IU

TNPA x rate* =

+ Sum of net positive adjustments

to creditable expenditure and

credit groupings:

= Total IU

* Highest rate in effect for the reviewed year under section 1 or 11.

Paperwork Reduction Act Notice. We ask for the

information on this form to carry out the Internal Revenue

laws of the United States. You’re required to give us the

information. We need it to ensure that you’re complying

with these laws and to allow us to figure and collect the

right amount of tax.

You aren’t required to provide the information requested

on a form that is subject to the Paperwork Reduction Act

12

unless the form displays a valid OMB control number.

Books or records relating to a form or its instructions must

be retained as long as their contents may become

material in the administration of any Internal Revenue law.

Generally, tax returns and return information are

confidential, as required by section 6103. The time

needed to complete and file this form will vary depending

on individual circumstances. The estimated burden for

individual taxpayers filing this form is approved under

OMB control number 1545-0074 and is included in the

estimates shown in the instructions for their individual

income tax return.

Comments and suggestions. If you have suggestions

for making Form 8082 and/or these instructions simpler,

we would be happy to hear from you. You can send us

comments through IRS.gov/FormComments. Or you can

write to the Internal Revenue Service, Tax Forms and

Publications Division, 1111 Constitution Ave. NW,

IR-6526, Washington, DC 20224. Don’t send Form 8082

to this address. Instead, see How and When To File,

earlier.

Instructions for Form 8082 (Rev. 10-2025)