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.‘
To see federal register publication of amendment, click TD 9394: Correcting amendment to final regulations: Withholding related to foreign partners for effectively connected taxable income (June 11, 2020).
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.