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.
As required under the BBA legislation, the Maples Group maintains a substantial presence in the US, with our Delaware office established in 2011. Our US professionals have significant expertise in investment funds and the team has direct experience of successfully working through the IRS partnership audit process under the BBA regime.
The Maples Group's Delaware-based fiduciary team provides a full range of independent governance services, complemented by accounting, registered agency, and administrative support for investment funds and structured finance. Our capabilities in US corporate matters are strengthened by an institutional-grade infrastructure, innovative technology, and the reach of a global network spanning 15 offices.
If you have any questions about the partnership representative requirements, Maples Group services or any aspect of regulatory compliance in Delaware, please connect with one of the individuals listed, or your usual Maples Group contact.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
