Title 26, Internal Revenue CodeRelease 119-110
§6223 Partners Bound by Actions of Partnership
Title 26 › Subtitle F — Procedure and Administration › CHAPTER 63 — ASSESSMENT › Subchapter C — Treatment of Partnerships › PART I — IN GENERAL › § 6223
Summary
A partnership must pick one partner or other person who is U.S.-based to act as its partnership representative, or the Secretary will pick one; the partnership and all partners are bound by that representative’s actions and by any final decision.
Full Legal Text
Title 26, §6223
Internal Revenue Code, Source: USLM XML via OLRC
(a)Designation of partnership representative
Each partnership shall designate (in the manner prescribed by the Secretary) a partner (or other person) with a substantial presence in the United States as the partnership representative who shall have the sole authority to act on behalf of the partnership under this subchapter. In any case in which such a designation is not in effect, the Secretary may select any person as the partnership representative.
(b)Binding effect
A partnership and all partners of such partnership shall be bound—
(1)by actions taken under this subchapter by the partnership, and
(2)by any final decision in a proceeding brought under this subchapter with respect to the partnership.
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Prior Provisions
Prior section 6223 and 6224 were repealed by Pub. L. 114–74, title XI, § 1101(a), (g), Nov. 2, 2015, 129 Stat. 625, 638, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017. section 6223, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 649, related to notice to partners of proceedings. section 6224, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 651; amended Pub. L. 107–147, title IV, § 416(d)(1)(A), Mar. 9, 2002, 116 Stat. 55, related to partner participation in administrative proceedings, waiver of partner’s rights, and settlement agreements.
Statutory Notes and Related Subsidiaries
Effective Date
Section applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Pub. L. 114–74, set out as a note under section 6221 of this title.
Reference
Citations & Metadata
Citation
26 U.S.C. § 6223
Title 26, Internal Revenue Code
Last Updated
Sep 22, 2026
Release point: 119-110