Why Us?

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:

Meet Our Team

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.

Advanced Partnership Representative Services contemplate active representation. This level of services is designed for partnerships that either are currently under IRS examination, expect an IRS examination to arise, or need an impartial, professional individual to act on behalf of the partnership with the IRS. We will collaborate with your authorized IRS representative and take direction from a partner who has been given authority to provide us with direction on behalf of the partnership. A member of our team, all of whom have years of experience dealing with the IRS, will be appointed as the Designated Representative and 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
• Enter 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 US Partnership Representative as their partnership representative and a specific US Partnership Representative executive to serve as a designated individual.

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Learn More About How We Can Help You

You can count on us to be your advocates in the event the IRS initiates an examination of your partnership. Call 312-549-9919 or use our contact form to schedule your initial consultation.