Withholding Tax on Foreign Partners’ Share of Effectively Connected Income IRC Section 1446

One of the consequences of Trump’s Tax Reform is it’s treatment of Partnerships – particularly those with Foreign Partners.  Withholding is now required. A partnership (foreign or domestic) that has income effectively connected with a U.S. trade or business (or income treated as effectively connected) must pay a withholding tax on the effectively connected taxable […]

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