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of 8821/2848’s

Note:

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

Nominee Partnerships are not required to check the partnership box, file a Form 1065, or provide the Nominee partnership list, but they must check the nominee box and provide a list of the individuals or entities for which the nominee is an agent/representative.

When none of the partners filed the required tax return or extension, reject the partnership application.

If any one of the partners in the partnership failed to file, failed to provide tax disclosure authorization, filed as a non-resident, or filed an individual tax return claiming a foreign tax home (Form 2555 filed, see exception), issue certification with a list of the partners that filed as a U.S. resident.

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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