miércoles, 10 de septiembre de 2008

US: witholding tax in partnerships with US trade or business


CCH (cch.taxgroup.com) reports:

The latest fact sheet released by the IRS in its monthly International Tax Gap Series reminds partnerships with foreign partners of their withholding responsibilities with respect to partnership income. If a partnership is engaged in a U.S. trade or business, each foreign partner is treated as directly engaged in that business for federal income tax purposes. The partnership must pay a withholding tax based on foreign partners' allocable share of the partnership's effectively connected income, and each partner must file an appropriate U.S. income tax return. Withholding tax rates range from 15% to 35%, depending on the type of income.

IRS International Tax Gap Series: U.S. Tax Withholding on Effectively Connected Income Allocable to Foreign Partners

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