Partnership Representative

On April 14, 2021, the IRS released a memorandum clarifying that partners and partnership representatives of TEFRA or BBA partnerships are entitled to request and receive IRS administrative file records containing partnership returns and return information, including any supporting schedules, attachments, or lists which include identifying information of persons other than the requesting party.  This memorandum serves as guidance to taxpayers pending an update to the Internal Revenue Manual.

Internal Revenue Code section 6103(e) details which parties may access returns ...

On January 14, 2021, the IRS issued Notice 2021-13 to provide transition penalty relief to partnerships complying with new rules for reporting partners’ capital account balances.

Before the 2020 tax year, partnerships could report their partners’ capital accounts for the tax year using one of a variety of methods, such as tax basis, GAAP, or section 704(b) book. However, the 2020 Form 1065 Instructions (“the Instructions??) require partnerships to calculate and report all their partners’ capital accounts using the tax basis method. The Instructions explain that if a ...