Tax Traps for U.S. Partnerships With Foreign Partners: Distributions, Sale of Interests, Withholding and Reporting
IRC 871 and 881, IRC 1446(f), FIRPTA, IRC 864(c)(8), Issues for Tiered Partnerships, and More
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and other tax professionals an in-depth analysis of critical tax challenges for partnerships with foreign partners. The panel will discuss tax considerations when making partnership distributions to foreign partners, withholding and reporting requirements, recent IRS guidance, and issues for tiered partnerships, as well as offer planning techniques for transfers of interests by non-U.S. partners.
- Overview of key tax issues
- Issues for tiered partnerships
- Distributions and transfers of interest
- Estate planning issues
- Withholding and reporting
- Use of income tax treaties
The panel will review these and other key issues:
- What are the key tax challenges for U.S. partnerships with foreign partners?
- What issues arise when making distributions to foreign partners?
- How are transfers of foreign partners' interest treated under current U.S. tax law?
- What are the key estate planning issues?
- What are the withholding and reporting requirements for both the U.S. partnership and foreign partner?
- What issues arise for tiered partnerships?
- How can income tax treaties be used by foreign partners?
- What are the tax traps to avoid and best practices for tax counsel and advisers?
Rolando Garcia, JD, CPA
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for... | Read More
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for international individuals and businesses, identifying international tax incentives and advising multinational businesses on establishing a U.S. presence. Additionally, he is heavily relied on by his clients to navigate inbound and outbound practices, including pre-immigration planning for individuals, and more.Close
Darren J. Mills, Esq., CPA, ChFC, CLU
Mr. Mills has more than 20 years of experience advising both middle market companies and large multi-nationals... | Read More
Mr. Mills has more than 20 years of experience advising both middle market companies and large multi-nationals regarding complex federal and international tax issues. He also advises both strategic and financial buyers in tax due diligence and structuring as well as providing sell-side due diligence/structuring. He has taught classes on S Corporations at Seton Hall University and the University of Baltimore School of Law.Close