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IRS No Longer Requires Partnership Representative to Provide TIN

March 15, 2019

This is the first filing season under the new Centralized Partnership Audit Regime. The most frequent question we heard was—does the partnership representative or designated individual really have to provide his or her Social Security number on the Form 1065? Until yesterday, the answer was yes. But then the IRS changed the rules.

Under the previous rules, when a partnership designated a partnership representative it had to provide the partnership representative’s Social Security number or, if it was an entity, its Taxpayer Identification Number. If the partnership representative was an entity, it also had to identify a designated individual and provide that individual’s Social Security number.

Many people were concerned about having to provide the partnership representative’s or designated individual’s Social Security number because of privacy and identify theft concerns. Apparently, the IRS listened. On March 14, 2019, the IRS issued a supplement to its Form 1065 Instructions. Now, taxpayers may list all 0s when asked for the partnership representative’s or designated individual’s taxpayer identification number (e.g., 000-00-0000).

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Charles C. Hwang
Partner – Washington, D.C.
Phone: +1.202.624.2626