U.S. Individual Income Tax Return Forms

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).

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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.

• Positive and negative adjustments may only be netted
•
•
•

Step 4—Figure the Total Netted Partnership
Adjustments (TNPA)

• Each net positive adjustment with respect to a
•

Instructions for Form 8082 (Rev. 10-2025)

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

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.

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.

•

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.

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earlier.

Instructions for Form 8082 (Rev. 10-2025)