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Rachel Partain Explores Partnership Representatives on Strafford Webinar

February 13, 2020
Program:Partnership Representatives: IRS Regulations Under Section 6223 and Challenges for Pass-Through Entities
Event Sponsor:Strafford Publications
Registration:Click Here To Register


Recent IRS rules create a ripple effect on partnership designations, operating agreements, and potential tax liability. Counsel and advisers must have detailed knowledge of the scope of a partnership representative's role to avoid adverse tax consequences.

The application of the Section 6223 requirement that partnerships designate a representative with sole authority to act on behalf of the entity in matters related to IRS examinations requires careful consideration of a variety of factors. As a result, many partnerships modified existing partnership agreements and implemented a variety of compliance mechanisms to avoid unintended tax consequences in case of an IRS audit.

The final regulations provide clarity on essential items of concern, including allowing a disregarded entity to serve as a representative of the partnership and the removal of the capacity-to-act requirement for designated representatives along with extensive guidance on removing or replacing a partnership representative. The regs provide a roadmap for tax professionals to advise partnership clients on ensuring that the partnership representative can appropriately respond to the partnership's potential tax issues.

Listen as our experienced panel provides a thorough and practical guide to the IRS regulations on partnership representatives under Section 6223, IRS procedural and administrative processes for audits, notice requirements, and other high-priority considerations for partnerships.


  1. Overview of the IRS partnership audit regime
  2. Selection and responsibility of partnership representatives under Section 6223
  3. IRS final Section 6223 regulations
  4. Designating a disregarded entity as a partnership representative
  5. Failure to designate an eligible party as a partnership representative
  6. Terminating/replacing partnership representative
  7. Best practices and planning considerations for counsel in light of the final regulations

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