Under the Bipartisan Budget Act of 2015 ("BBA"), US
partnerships are required each year to appoint a US based
partnership representative, to act as a liaison with the Internal
Revenue Service ("IRS") and deal with tax matters as they
arise. The requirement to appoint a partnership representative
applies to both US and non-US investment funds structured using
partnerships that file a US tax return.
For 2024 tax returns, the deadline for partnerships which have
filed an extension to make an election to the IRS is 15 September
2025.
The Maples Group's Delaware office provides a partnership
representative solution to clients, supported by US tax advisors,
with highly experienced fiduciary professionals acting as
designated individuals. This service is provided where clients do
not have a qualified individual based in the US that is willing to
serve in this capacity.