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Form 8804 Fill in Version Annual Return for Partnership Withholding Tax Section 1446

Form 8804 Fill in Version Annual Return for Partnership Withholding Tax Section 1446

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today we are going to talk about new section 1446 f related to withholding taxes on sales of partnerships engaged in us business before we get into the new rules it's helpful to provide an overview of the existing rules regarding ongoing earnings of partnerships as opposed to sales of partnerships let's say we have a u.s. partnership that operates a u.s. business the partnership is 50 percent owned by a u.s. partner and 50 percent owned by a foreign partner under Section 8 75 1 the foreign partner is deemed to be engaged in a u.s. business because the partnership is engaged in a u.s. business it doesn't matter whether the partnership is a u.s. partnership or a foreign partnership what matters is that the partnership is engaged in a u.s. business section 1446 a provides that the partnership must withhold on income that is effectively connected with the u.s. business that's allocable to the foreign partner the partnership files forms ad 804 eighty eight oh

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