Also known as:withholding on foreign partnerships · foreign partnership withholding · section 1446 · foreign partnership tax withholding
Written by attorneys · grounded in primary & secondary sources — see below
A category of foreign persons eligible to assume responsibility for U.S. tax withholding on payments to foreign payees.
Sources & Authorities· 6 primary sources
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Statutes
Study Supplements
How it applies
Common Examples
2
Partnership Assumes Withholding Duty
Winter Wolfe receives a distribution from a foreign partnership. The partnership files a notice asserting it will handle withholding. The withholding agent accepts the filing and withholds at the partnership's reported rate.
Foreign Entity Removes Action
Wade Watson receives a payment from a foreign partnership. The partnership elects to perform its own withholding on the payment. The withholding agent relies on the election and issues the net amount to the payee.
Common questions
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Test Yourself
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Practice Questions1
Frequently Asked
2
What entities qualify as withholding foreign partnerships?+
They are foreign persons that may assume responsibility for withholding on payments to foreign payees when proper documentation is provided.
How does a withholding foreign partnership reduce the withholding rate?+
It may claim a reduced rate under a tax treaty by supplying appropriate documentation to the withholding agent.
Civil ProcedureJurisdiction and venue · Federal subject-matter jurisdiction (federal question, diversity, supplemental, and removal)UBEIntermediate