In November of 2015, President Obama signed the Bipartisan Budget Act of 2015 ("BBA15") into law. There are numerous provisions of BBA15 that apply to the taxation of partnerships and pass-through entities, such as Limited Liability Companies. However, the vast majority of the changes are aimed at improving the Internal Revenue Service's ability to audit and collect tax from large partnerships. The most significant change allows for the Service to collect for underpayment