Partnership Representative Services Offered

United States Partnership Representative, Inc. (“USPR”) provides professional Partnership Representative and Designated Individual services to partnerships. Working with Moore Tax Law Group, LLC, USPR also provides partnerships with an authorized representative that can receive all IRS communications sent to either the partnership or its Partnership Representative.

The Bipartisan Budget Act of 2015 (“BBA”) requires partnerships to designate a Partnership Representative who is the primary point of contact for all Internal Revenue Service examinations. Where an entity is designated as the Partnership Representative, the BBA also requires the Partnership Representative to appoint a Designated Individual as a single point for IRS contact. Unlike the Tax Matters Partner under the former IRS partnership audit regime, Partnership Representatives need not be a partner in the partnership. Instead, a Partnership Representative must have substantial presence in the United States. The Partnership Representative must make themselves available to meet in person with the IRS, and must have a United States Taxpayer Identification Number, a United States physical address, and a telephone number with a United States Area Code. The USPR team has decades of experience representing clients before the IRS. It offers two levels of professional partnership services, advanced and basic.

Advanced Partnership Representative Services contemplate active representation. This level of service is designed for partnerships that need an impartial professional Partnership Representative to act on behalf of the partnership in an examination that is already underway or imminently expected to arise. Advanced Partnership Representative Services may also be appropriate following a change in control. USPR will collaborate with the partnership’s authorized representative (its attorney, CPA, or enrolled agent) and take direction from a partner who has been given authority to direct USPR on behalf of the partnership. A member of our team, all of whom have years of experience dealing with the IRS, will act at your direction in an IRS exam, including:

• Preparing for and participating in IRS Interview of Partnership Representative
• Agreeing to Notice of Proposed Partnership Adjustments (NOPPA)
• Waiving modification period
• Making push-out election
• Entering into settlement agreement
• Extending statute of limitations period
• Extending modification period

Basic Partnership Representative Services are available to partnerships that are not currently under IRS examination. Those partnerships are permitted to designate USPR as their Partnership Representative and a specific USPR executive to serve as a Designated Individual.

Effective Communication And Representation
The IRS will send all communications regarding IRS examinations to the Partnership Representative except a notice of selection for examination, which is sent only to the partnership. The IRS does not send notices that are unrelated to examinations to the Partnership Representative.

To ensure our clients receive timely notification of all IRS communications, together with an explanation of what the communication is and what, if any, action needs to be taken in response to the communication, USPR, Inc., works with Moore Tax Law Group, LLC to obtain the authorization from the IRS necessary to receive communications addressed to both the partnership and the Partnership Representative.

Most administrative matters that are a natural consequence of a clerical error or a minor dispute can be resolved in two hours or less. This isn’t a hard and fast rule, but, in general, if an IRS dispute can’t be resolved in one to two hours, it is going to require settling in for a long road ahead. USPR, Inc. and Moore Tax Law Group, LLC together provide their clients up to two hours of IRS dispute resolution for each tax year, if needed.

• For taxpayers who engage USPR and don’t already have an authorized representative (such as an attorney, CPA, or enrolled agent), Moore Tax Law Group, LLC will act as your partnership’s authorized representative before the IRS. Doing so will ensure:
• Ability to receive copies of IRS communications sent to the partnership but not the Partnership Representative, and
• Access to IRS account records through the IRS’s electronic records service for practitioners, Transcript Delivery System (TDS).
• All IRS communications sent to both the Partnership Representative and the partnership will be provided to the partnership.
• We will provide your partnership with an explanation of what each IRS notice means and what, if any, action is required to respond.
• We will alert your partnership immediately if we are contacted by the IRS.
• We will get your authorization and direction regarding what, if any, response to provide to IRS requests for information or payment.