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 […]