More than half of House Republicans have co-sponsored a bill to “blow up” the US tax code at the end of 2019 in order to force Congress to start over . . . . The IRS wants comments by May 16 on tax issues that it should put on a priority guidance list to try to address over its next “business plan year” that runs from July 1, 2016 through June 30, 2017. The request for comments is in Notice 2016-26. An unusually large number of issues of interest to the project finance community are on the current business plan that runs through June 30. (See the September 2015 NewsWire article, An Unusually Large Number.) Most have not been addressed yet and are likely to remain on the list for next year . . . . New partnership audit rules that take effect in 2018 will require some rewriting of partnership agreements and have the potential to complicate future sales of interests in existing partnerships, loans where a partnership is the borrower, and the allocation of risk and tax contest provisions in tax equity deals. The IRS is working on regulations to implement them and asked in Notice 2016-23 for comments by April 15 . . . . Many partnerships are expected to try to opt out of the new partnership audit rules. They would allow the IRS to collect any back taxes on audit from the partnership rather than have to chase each partner for its share. This opt-out election is not available if any of the partners is itself a partnership unless the IRS says otherwise in regulations. The IRS is not expected to be very generous in allowing opt-out elections. The Joint Committee on Taxation suggested in its “blue book” summarizing tax legislation enacted in 2015 that the opt-out election will also be unavailable, unless the IRS says otherwise, in cases where a partnership owns a project through a wholly-owned special-purpose limited liability company. This is a common ownership structure in the power industry. The blue book was released in March.