Advocates Your Partnership Can Count On
The legal concept of a partnership representative is fairly new. The 2019 filing season was the first time partnerships, tax professionals and the IRS grappled with the Bipartisan Budget Act, or BBA, and how implementing those new rules will impact partnerships. But one thing about this role is certain: The partnership representative has broad, sweeping and unilateral powers to represent and bind the partnership in an IRS examination.
The attorneys at US Partnership Representative, Inc., have been working in this field from the very beginning. Our team comprises professionals who have spent their careers representing clients in IRS disputes. Representing taxpayers in tax disputes is what we do. We are not a mail stop, we are experienced tax advocates. Learn more about our team here:
The Department of the Treasury explains in the preamble to the final regulations defining the rules applicable to the partnership representative under I.R.C. § 6223, “the responsibilities and authority of a partnership representative are generally applicable only if a partnership is selected for examination as part of an administrative proceeding or the partnership files an AAR.” (source). Put another way, the partnership representative has no role unless and until the IRS initiates an examination. At US Partnership Representative, Inc., we have the experience to help guide your partnership through the morass of an IRS examination.
Belts And Suspenders
Our partnership with Moore Tax Law Group ensures that your partnership will not only receive the best quality partnership representation available, but also receive notification of all communications sent to both the partnership representative and the partnership. The final regulations governing partnership representatives make clear that the partnership representative has absolute and sole authority to interact with the IRS in an examination. As such, all communications regarding examinations are sent to the partnership representative, except one – a notice of selection for examination. This notice is instead sent to the partnership, and the partnership representative does not receive a copy.
By partnering with Moore Tax Law Group, LLC, US Partnership Representative, Inc., will be able to receive copies of all communications received from the IRS, including those addressed to the partnership representative and to the partnership. Taking this belts-and-suspenders approach ensures that the partnership will have the ability to timely receive all communications from the IRS, no matter where in the world the partnership is located.