I n November, 2015, Congress repealed TEFRA and enacted an entirely new statutory regime covering examination, litigation, and payment of taxes for partnerships and entities taxed as a partnership.
“Partnership Representative” will be the new designated liaison between partnerships/limited liability companies and the Internal Revenue Service. The partnership representative has broader authority to handle matters before the IRS, including managing and settling tax disputes, litigating in the U.S. Tax Court or U.S. district courts, payment of additional taxes owed, and filing refund claims.
F or those seeking information, this website will be a resource with articles, programs, and insights on how to address the new provisions of the Bipartisan Budget Act of 2015. In light of this legislation, partnerships and partners should now evaluate the current provisions of their partnership agreements and make fundamental changes to the tax procedure provisions. Doing so now will help to reduce and manage the partnership’s potential tax obligations and administrative costs and define the rights and responsibilities of partners, the partnership, and the partnership representative.