The Coronavirus Aid, Relief, and Economic Security Act
("CARES Act") offers tax relief which may be beneficial
to entities taxed as partnerships. These provisions include (i)
retroactive relief for entities taxed as partnerships by
temporarily increasing the interest deduction limitation from 30%
to 50% of adjusted taxable income, and (ii) clarifying that
"qualifying investment property" qualifies for bonus
depreciation. These changes are retroactive to the 2018 and 2019
tax years. On April 8th, the IRS issued Rev. Proc. 2020-23 to
provide procedures for partnerships subject to the Centralized
Partnership Audit Regime enacted in the Bipartisan Budget Act of
2015, which includes partnerships that either did not or could not
elect out of the Centralized Partnership Audit Regime provisions
("BBA Partnerships"), to allow a BBA Partnership to amend
its Form 1065 U.S. Return of Partnership Income. In the absence of
Rev. Proc. 2020-23, a BBA Partnership could not amend its
