13 results for "1446"

Table of contents.

Withholding tax on foreign partners' share of effectively connected taxable income.

Determining a partnership's effectively connected taxable income allocable to foreign partners under section 704.

Time and manner of calculating and paying over the 1446 tax.

Publicly traded partnerships.

Tiered partnership structures.

Special rules to reduce a partnership's 1446 tax with respect to a foreign partner's allocable share of effectively connected taxable income.

Applicability dates.

General rules.

Withholding on the transfer of a non-publicly traded partnership interest.

Partnership's requirement to withhold under section 1446(f)(4) on distributions to transferee.

Withholding on the transfer of a publicly traded partnership interest.

Liability for failure to withhold.