WHO IS ELIGIBLE TO BE A PARTNERSHIP REPRESENTATIVE?

A partnership representative must have a substantial presence in the United States. For purposes of partnership representatives, “substantial presence” requires the partnership representative to have a United States taxpayer identification number, a telephone number with a United States area code, a United States street address, and the ability to make themselves available to meet with the Internal Revenue Service(IRS) in person in the United States at a reasonable time and place as determined by the IRS.

If your partnership has no partners with a “substantial presence” in the United States, the partnership must designate a professional partnership representative or some other nonpartner who has a substantial presence to be the partnership representative. US Partnership Representative, Inc., offers that service to partnerships worldwide. Our experience with U.S. tax law runs deep.

Under TEFRA, partnerships were required to choose a partner to be the Tax Matters Partner or TMP. The TMP had to be a partner in a partnership. The BBA repealed TEFRA, and the role of TMP has been eliminated.