Designate or change a partnership representative

Find how to designate or change a partnership representative for a partnership under the Bipartisan Budget Act (BBA) centralized partnership audit regime.

About the partnership representative

A partnership must designate a partnership representative on its tax return for each taxable year unless it makes a valid election out of the centralized partnership audit regime (BBA).

The designation of a partnership representative for one taxable year is effective only for that taxable year.

The partnership representative must have substantial presence in the United States.

Authority

The partnership representative has the sole authority to act on behalf of the partnership for purposes of BBA partnership audit procedures. The partnership and the partners are bound by the actions of the partnership representative under the BBA.

Actions

The actions of the partnership representative on behalf of the partnership and the partners under subchapter C of chapter 63 of the Internal Revenue Code include but are not limited to:

Extending the statutory periods for making adjustments by agreement
Entering into a settlement agreement
Agreeing to a Notice of Proposed Partnership Adjustments (NOPPA)
Requesting modification of an imputed underpayment
Extending the modification period by agreement
Waiving the modification period
Agreeing to a notice of final partnership adjustment (FPA) and/or waiving the FPA
Making a push out election

Who’s eligible

A partnership may designate any person, an entity or itself as a partnership representative, but they are required to have a substantial presence in the United States.

If an entity is designated as a partnership representative, the partnership must also appoint a designated individual to act on the entity’s behalf. The designated individual must also have a substantial presence in the U.S. In this guidance, any reference to the partnership representative includes the designated individual.

Substantial presence

For a partnership representative or designated individual to have substantial presence in the United States, all the following must be true:

The entity/individual has a U.S. taxpayer identification number.
The entity/individual has a U.S. street address and a telephone number with a U.S. area code.
The partnership representative or designated individual acting on behalf of an entity partnership representative makes themselves available to meet in person with the IRS in the United States at a reasonable time and place as determined by the IRS in accordance with Treasury Regulation § 301.7605-1.

Note: If the partnership representative is an entity, that entity must be in legal existence.

How to designate a partnership representative

A partnership representative must be designated for each respective year on the partnership’s return.
To designate a partnership representative, enter their name, U.S. address and phone number on:

Form 1065, U.S. Return of Partnership Income, ‘Designation of partnership representative’ section after Schedule B or
Form 1066, U.S. Real Estate Mortgage Investment Conduit (REMIC) Income Tax Return, ‘Designation of partnership representative’ section after Schedule M

There can only be one partnership representative at any time during the tax year. The designated partnership representative remains in effect until the designation is terminated by a valid revocation, a valid resignation, or a determination by the IRS that the partnership representative designation is not in effect. If the designation of a partnership representative terminates, the validity of any action taken by that partnership representative during the period prior to such termination remains in effect.

How to change a partnership representative

Use Form 8979, Partnership Representative Revocation, Designation, and Resignation to make a change:

Revoke a partnership representative

To revoke Entity Partnership Representative

Select boxes for either option 1(a)(i) or option 1(a)(ii) on Form 8979 and follow the instructions for the selected option (shown below):

Option 1(a)(i), select box (1), box (a) and box (i). The Partnership is Revoking the Entity Partnership Representative and Designating a successor Entity Partnership Representative and Appointing a new Designated Individual. Complete Part II, Section A and Part III, Section A. Sign Part IV, Section A.
Option 1(a)(ii), select box (1), box (a) and box (ii). The Partnership is Revoking the Entity Partnership Representative and Designating an Individual Partnership Representative. Complete Part II, Section A and Part III, Section B. Sign Part IV, Section A.

To revoke Individual Partnership Representative

Select boxes for either option 1(b)(i) or option 1(b)(ii) on Form 8979 and follow the instructions for the selected option (shown below):

Option 1(b)(i), select box (1), box (b) and box (i). The Partnership is Revoking the Individual Partnership Representative and Designating an Entity Partnership Representative and Appointing a Designated Individual. Complete Part II, Section B and Part III, Section A. Sign Part IV, Section A.
Option 1(b)(ii), select box (1), box (b) and box (ii). The Partnership is Revoking the Individual Partnership Representative and Designating a successor Individual Partnership Representative. Complete Part II, Section B and Part III, Section B. Sign Part IV, Section A.

To revoke Designated Individual

Select boxes for option 1(c) on Form 8979 and follow the instructions for the selected option (shown below):

Option 1(c), select box (1) and box (c). The Partnership is Revoking the Designated Individual and Appointing a successor Designated Individual. Complete Part II, Section A and Part III, Section A. Sign Part IV, Section A.

Resign as a partnership representative

Select boxes for either option 2(a) or option 2(b) on Form 8979 and follow the instructions for the selected option (shown below):

Option 2(a), select box (2) and box (a). Entity Partnership Representative is Resigning. Complete Part II, Section A and Sign Part IV, Section B.
Option 2(b), select box (2) and box (b). Individual Partnership Representative is Resigning. Complete Part II, Section B and Sign Part IV, Section C.

Resign as a designated individual

Select the box for option 3 on Form 8979 and follow the instructions for the selected option (shown below):

Option 3. The Designated Individual is Resigning. Complete Part II, Section A and sign Part IV, Section D.

Designate a partnership representative

If no partnership representative designation is in effect, select boxes on Form 8979 for either option 4(a) or option 4(b) and follow the instructions for the selected option (shown below):

Option 4(a), select box (4) and box (a). The partnership is Designating an Entity Partnership Representative and Appointing a Designated Individual. Complete Part III, Section A and Sign Part IV, Section E.
Option 4(b), select box (4) and box (b). The partnership is Designating an Individual Partnership Representative. Complete Part III, Section B and Sign Part IV, Section E.

When to submit Form 8979

If you’re a partnership

You may submit Form 8979 in these situations:

Directly to the current IRS employee point of contact (for example, revenue agent, appeals officer, counsel) after the issuance of either Letter 2205-D, Initial Contact to Schedule Appointment-Partnership Returns; or Letter 5893, Notice of Administrative Proceeding-Partnership; or Letter 5893-A, Notice of Administrative Proceeding-Partnership Representative.
With an administrative adjustment request (AAR) filed for a reason other than only making a revocation, prior to the issuance of Letter 2205-D, Letter 5893, or Letter 5893-A.
With a Form 8985, Pass-Through Statement — Transmittal/Partnership Adjustment Tracking Report, submitted by a pass-through partnership that has not elected out of the Bipartisan Budget Act (BBA).
Note: See the Instructions for Form 8985 for how to submit Form 8979 in response to an exam, compared to in response to an AAR filing.
With Form 8988, Election for Alternative to Payment of the Imputed Underpayment - IRC Section 6226.
With Form 921-M, Consent Fixing Period of Limitation To Make Partnership Adjustments (if submitting Form 8979, attach it to the statute extension and return it to the IRS point of contact).
Note: If after submitting Form 921-M and Form 8979 to your IRS employee point of contact (for example, Rev. Proc. 92-29 Coordinator, Revenue Agent Reviewer, etc.), you receive Letter 2205-D, Letter 5893, or Letter 5893-A from a different IRS employee point of contact (for example, revenue agent, appeals officer, counsel), provide a copy of the previously submitted Form 8979 to the second IRS employee point of contact.
Form 8979 may also be submitted any time a BBA partnership makes a request of the IRS that requires the partnership to extend a statute. Examples include, but are not limited to, private letter ruling requests pertaining to late elections to self-certify a qualified opportunity fund and elections to postpone determination as to whether the presumption applies that an activity is engaged in for profit.

If you’re a partnership representative or designated individual

The Form 8979 can only be submitted by the partnership representative or designated individual to resign. In the event a partnership representative or designated individual is resigning, Form 8979 should be submitted directly to the current IRS employee point of contact after the issuance of Letter 2205-D, Letter 5893, or Letter 5893-A.

Note: If the IRS notifies the partnership that there is no designation in effect, the partnership has 30 days from the date the IRS mails the notification to submit Form 8979. If the partnership fails to designate a partnership representative (and appoint a designated individual, if applicable), the IRS will designate one.

Where To File Form 8979

To file Form 8979 with an AAR, follow the steps in "How to file an AAR".

Otherwise, mail or fax Form 8979 to the attention of the current IRS employee point of contact (for example, revenue agent, appeals officer, counsel).

If your address changed

The information you provide on Form 8979 won't change your last known address with the IRS.

To change your address of record for:

Individual - Use Form 8822, Change of Address
Business - Use Form 8822-B, Change of Address or Responsible Party—Business

How to authorize power of attorney (Form 2848)

If the partnership representative wants to appoint a person as power of attorney to represent the partnership representative in its capacity as partnership representative for the BBA partnership, the partnership representative must submit a Form 2848.

A new partnership representative cannot simply retain a prior power of attorney appointed by the previous partnership representative. If the new partnership representative wants to continue to use a prior power of attorney, the partnership representative should submit a new Form 2848 appointing the prior power of attorney.

To properly prepare Form 2848, please refer to IRM 4.31.9.7.10.1, Form 2848, For Items Within the Scope of the BBA Regime.

Regulations

Return to BBA Centralized Partnership Audit Regime

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