U.S. Partnerships With Foreign Partners: Navigating Withholding, Informational Reporting, and Payment Requirements
Determining ECI, FDAP, FIRPTA Income Classifications, Treaty Benefits, Basis Adjustments, and Sale Treatment
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and compliance professionals with a thorough and practical guide to the issues faced by U.S. partnerships with foreign partners. The panel will discuss the various withholding and reporting requirements with respect to non-U.S. partners.
Outline
- Income taxation of partnerships with foreign partners
- Blocker corporations and foreign partnerships
- Partnership Chapter 3 withholding and reporting
- Partnership Chapter 4 (FATCA) withholding and reporting
- IRC Section 1446(f) withholding requirements
- Filing requirements
Benefits
The panel will discuss these and other important issues:
- Documentation partnerships must obtain from foreign partners
- Withholding requirements for effectively-connected income for foreign partners under Section 1446
- Withholding requirements for FDAP income under Chapters 3 and 4, including the impact of treaty positions on these obligations
- Withholding requirements under FIRPTA and Section 1446(f) upon transfers of partnership interests
- Impact of blocker corporations and other intermediate entities
- Filing requirements
Faculty
Jack R. Brister, TEP
Managing Member
International Wealth Tax Advisors
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset... | Read More
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.
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Joshua S. Kaplan
Senior Managing Director
KPMG US
Mr. Kaplan provides advice on a wide range of inbound and outbound international tax issues, with a particular focus on... | Read More
Mr. Kaplan provides advice on a wide range of inbound and outbound international tax issues, with a particular focus on inbound investment, including FIRPTA, section 892, branch profits tax, U.S. trade or business and effectively connected income (“ECI”) determinations, treaty qualification and permanent establishment issue, sales of ECI partnerships by foreign persons, and chapter 3 withholding. He routinely advises clients on buy-side and sell-side FIRPTA due diligence issues, FIRPTA withholding and reporting requirements, tax-efficient structuring for funds and REITS with foreign investors, and the application of the FIRPTA nonrecognition rules to corporate formation, restructuring, and divestiture transactions. Josh also has significant experience with U.S. real property holding corporation determinations, particularly in the power generation, electric transmission and distribution, and telecommunications industries.
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