Treasury and the IRS have published a correcting amendment to final regulations related to foreign partners for effectively connected taxable income on June 11, 2020. The summary for the amendment is as follows:
This document contains corrections to Treasury Decision 9394, which was published in the Federal Register on Tuesday, April 29, 2008. Treasury Decision 9394 contained final regulations regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership’s obligation to pay withholding tax under section 1446 on effectively connected taxable income allocable under section 704 to such partner.
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Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.
