12/12/2023 0 Comments W8imy withholding statementFor special rules that may apply in determining the amount of 1446 tax due with respect to a partner, see § 1.1446–6. For special rules applicable to tiered partnership structures, see § 1.1446–5. For special rules applicable to publicly traded partnerships, see § 1.1446–4. If the partnership has ECTI allocable under section 704 to one or more of its foreign partners, the partnership computes its 1446 tax, pays over 1446 tax, and reports the amount paid in accordance with the rules in § 1.1446–3. If the partnership has one or more foreign partners, it then determines under § 1.1446–2 whether it has ECTI any portion of which is allocable under section 704 to one or more of the foreign partners. If the partnership does not have any foreign partners (including any person presumed to be foreign under paragraph (c) of this section and any domestic trust treated as foreign under § 1.1446–3(d)) during its taxable year, it generally will not have a 1446 tax obligation. The partnership determines whether it has any foreign partners in accordance with paragraph (c) of this section. In general, a partnership determines its 1446 tax as follows. (b) Steps in determining 1446 tax obligation. If a domestic or foreign partnership has effectively connected taxable income (ECTI) as computed under § 1.1446–2 for any partnership tax year, and any portion of such taxable income is allocable under section 704 to a foreign partner, then the partnership must pay a withholding tax under section 1446 (1446 tax) at the time and in the manner prescribed in this section, and §§ 1.1446–2 through 1.1446–6. § 1.1446-1 Withholding tax on foreign partners' share of effectively connected taxable income.
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