|
Partnerships
A foreign or domestic partnership that has income
effectively connected with a US trade or business
(or income treated as effectively connected) must
pay a withholding tax on the effectively connected
taxable income that is allocable to its foreign
partners.
A
foreign partner can be a nonresident alien individual,
foreign corporation, foreign partnership, or foreign
estate or trust.
A
publicly traded partnership must withhold tax
on actual distributions of effectively connected
income, unless it chooses to withhold on effectively
connected income allocable to its foreign partners.
This withholding tax does not apply to income
that is not effectively connected with the partnership's
US trade or business. Income that is not effectively
connected income is subject to withholding tax
at 30% or a lower treaty rate.
The withholding tax that a partnership is required
to pay for the partnership's tax year is based
on its effectively connected taxable income that
is allocable to its foreign partners for that
tax year.
The
amount of a partnership's effectively connected
taxable income that is allocable to a foreign
partner is the foreign partner's distributive
share of the partnership's gross effectively connected
income reduced by the partner distributive share
of partnership deductions for the year.
BACK
TO TOP
|
