Page 53 - The TEFRA Partnership Audit Rules Repeal:
P. 53
Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative
• Multiple Questions:
− Who can be the partnership representative?
− What are the qualifications of the partnership representative? Affidavit of substantial presence in the U.S.; annual ratification
− Must the partnership representative be a partner?
− What is the term of the partnership representative?
− How is the partnership representative selected?
− How is the partnership representative removed?
− Is removal limited to “cause”? What is “cause”?
− Can the partnership representative resign?
− What is the resignation procedure?
− What are the fiduciary duties of the partnership representative?
Copyright © 2016 Kostelanetz & Fink, LLP Coming changes to IRS Audits of partnerships 44
