The U.S. Internal Revenue Service (IRS) has issued new rules regarding the obligation of a partnership to pay a withholding tax on effectively connected taxable income (ECTI) allocable to a foreign partner. The proposed regulations will affect partnerships engaged in a U.S. trade or business ...
effectively connected income on filing a true and accurate return. While the statutes underlying these regulations have been in force for many years, the ... LE Shoenthal,S Tenenbaum - Nonresident Aliens and Foreign Corporations May Be Subject to Full Income Taxes on Their Gross U.S. Receipts...
Section 1446 Regulations; Withholding on Effectively-Connected Taxable Income Allocable to Foreign PartnersMark E. Matthews
Withholding on Allocations of Effectively Connected Taxable Income to Foreign PartnersIn this report the NYSBA tax section discusses the final, temporary, and proposed Treasury regulations issued under section 1446, relating to the withholding byBar Association, New York State...
According to the author, nonresident alien individuals are taxable only on those incomes generated through a business or trade connected with the United States. Likewise, their income is taxable that could qualify as fixed or determinable annual or periodical (FDAP) income.Williamson...