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Information provided on this site is for general guidance only and
is often simplified. Actual IRS procedures are complex, and taxpayers
should obtain professional assistance or use IRS sources for complete
information.
Foreign
Corporations A
foreign corporation, for US tax law purposes, is
any corporation not organized under the laws of
the United States.
Partnerships Partnerships
have to withhold tax from the shares of foreign
partners.
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.
Law & Tax
News: Daily news and background data on tax and legal developments
for international business.
Offshore-e-com:
A topical guide to offshore e-commerce focused on tax and regulation.
Lowtax Library:
One of the web's largest and most authoritative business and investment
information sources.
US Tax Network:
The resource for free online US taxation information, covering: corporate
tax, individual tax, international tax, expatriates, sales and e-commerce
tax, investment tax.
Personal
Business Tax Guide: Providing essential tax news and information
on business for contractors, entrepreneurs, professionals, small businesses,
artists, sportspersons and entertainers.
Offshore Trusts
Guide: OTG publishes news, features and newsletters on the use of
offshore trust structures.
One of the web's
largest and most authoritative business and investment information
sources. Alongside topical, daily news on worldwide
tax developments, you can receive weekly newswires or
access up-to-date intelligence
reports on a range of legal, tax and investment subjects.
Our 16 constantly
updated intelligence reports cover every important aspect
of 'offshore' and international tax-planning in depth, including
banking secrecy, the EU's savings tax directive, offshore
funds, e-commerce, offshore gaming and transfer pricing. Reports
are available for immediate downloading or as subscription
services with news pages.
IMPORTANT NOTICE:
THE LOWTAX NETWORK has taken reasonable care in sourcing and presenting
the information contained on this site, but accepts no responsibility
for any financial or other loss or damage that may result from its use.
In particular, users of the site are advised to take appropriate professional
advice before committing themselves to involvement in offshore jurisdictions,
offshore trusts or offshore investments. All materials on this site copyright
The Lowtax Network 1999 - 2012.
All content on this
site has been provided by BSIRN.
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