SECTION 7. OPTION PROVIDED TO

ELIGIBLE BBA PARTNERSHIPS FOR THE 2022, 2023 AND 2024 TAXABLE YEARS

.01 Scope . The filing and furnishing option provided by this section 7 applies to BBA partnerships described in section 7.03 of this revenue procedure (eligible BBA partnerships) for the taxable years described in section 7.04 of this revenue procedure.

.02 Option to file amended Form 1065 . Eligible BBA partnerships may implement this revenue procedure by filing an amended partnership return and furnishing corresponding Schedules K-1 instead of filing an AAR. The amended Form 1065 may take into account tax changes provided by this revenue procedure as well as any other tax attributes to which the partnership is entitled by law. This revenue procedure allows eligible BBA partnerships the option to file an amended Form 1065 instead of an AAR; it does not prevent an eligible BBA

partnership from filing an AAR to obtain the benefits of this revenue procedure or any other tax benefits to which the partnership is entitled. An eligible BBA partnership that files an amended Form 1065 pursuant to this revenue procedure remains subject to the centralized partnership audit procedures enacted by the BBA.

.03 Eligible BBA partnerships . The filing and furnishing option provided in this section 7 is available only to BBA partnerships that filed Forms 1065 and furnished Schedules K-1 for the partnership taxable years beginning in 2022, 2023, or 2024 prior to the issuance of this revenue procedure. A BBA partnership that receives an amended Schedule K-1 from another partnership that filed an amended Form 1065 pursuant to this revenue procedure may also file an amended Form 1065 to take into account the adjustments in the amended Schedule K-1 as long as it also meets the requirements of this revenue procedure. For purposes of § 6222, the amended Form 1065 replaces any prior return (including any AAR filed by the partnership) for the taxable year for purposes of determining the partnership’s treatment of partnership-related items. See section 7.05(3) of this revenue procedure for a special rule regarding partnerships that have previously filed AARs for an affected taxable year.

.04 Eligible taxable years . The filing and furnishing option provided in this revenue procedure applies only to partnership taxable years that began in 2022, 2023, or 2024. .05 Procedure . (1) Filing requirements . To take advantage of the option to file an amended Form 1065 provided by this section 7, an eligible BBA partnership must, in addition to meeting the other applicable requirements set forth in this revenue procedure, file a Form 1065 (with the “Amended Return” box checked) and furnish corresponding amended Schedules K‑1. The eligible BBA partnership should follow the nonBBA partnership instructions for filing an amended Form 1065. The amended Form 1065 filed pursuant to this section 7 must be filed, and the corresponding Schedules K-1 must be furnished, by the deadlines set forth in section 4.01(3) of this revenue procedure, and the rules applicable to AARs, including the § 6227(c) filing period, do

not apply to an amended Form 1065 filed under this section 7. As set forth in section 4.01(2) of this revenue procedure, the eligible BBA partnership must clearly indicate the application of this revenue procedure on the amended Form 1065 and write “FILED PURSUANT TO REV. PROC. 2026-17” at the top of the amended Form 1065 and attach a statement with each Schedule K-1 sent to its partners with the same notation. The eligible BBA partnership may file electronically or by mail but filing electronically will allow for faster processing of the amended Form 1065.

(2) Special rule for eligible BBA part- nerships whose returns are under exam- ination . If an eligible BBA partnership is currently under examination for a taxable year beginning in 2022, 2023, or 2024 and wishes to take advantage of the option to file an amended Form 1065 provided by this section 7, the partnership may do so only if the partnership sends notice to the revenue agent coordinating the partnership’s examination in writing that the partnership seeks to use the amended Form 1065 option described in this revenue procedure prior to or contemporaneously with filing the amended Form 1065 as described in this section 7. The partnership must also provide the revenue agent with a copy of the amended Form 1065 upon filing.

(3) Special rule for eligible BBA part- nerships that have previously filed an AAR . If an eligible BBA partnership has previously filed an AAR and wishes to file an amended Form 1065 pursuant to this revenue procedure for the same taxable year, the partnership should use the items as adjusted in the AAR, where applicable, in lieu of any reporting from the originally filed partnership return.