September 15 Is Almost Here — Is Your Partnership Representative in Place?
For many partnerships and investment funds, September 15 is an important tax filing deadline. As tax returns are being finalized, there is one item that should not be overlooked: the designation of the Partnership Representative. Under the federal partnership audit regime established by the Bipartisan Budget Act of 2015, partnerships subject to the regime generally designate a Partnership Representative on their federal partnership tax return. This is not simply an administrative title. The Partnership Representative has significant authority to act on behalf of the partnership in dealings with the Internal Revenue Service under the centralized partnership audit rules. For investment managers, fund administrators, tax professionals, and offshore funds with U.S. […]
U.S. Partnership Representative Services: What Partnerships Need to Know
Foreign partnerships and non-U.S. fund managers with U.S. tax filing obligations face a unique compliance challenge: meeting the IRS requirement to designate a U.S. Partnership Representative with a substantial presence in the United States. Under the centralized partnership audit regime, the Partnership Representative has exclusive authority to act on behalf of the partnership during IRS examinations. For non-U.S. entities, appointing a qualified and reliable U.S. representative is not optional—it is a critical compliance requirement. Understanding the U.S. Partnership Representative Requirement The IRS requires partnerships to designate a Partnership Representative who: For foreign partnerships and non-U.S. fund managers, this requirement can be difficult to satisfy internally, particularly when management and operations […]