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

A live 110-minute CPE webinar with interactive Q&A


Wednesday, October 4, 2017 (in 12 days)
1:00pm-2:50pm EDT, 10:00am-11:50am PDT


This webinar 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 requirements for non-U.S. partners, treaty structures (including limitation on benefits provisions), and often overlooked capital account adjustments particular to foreign partners.

Description

Tax advisers serving partnerships with foreign (non-U.S.) partners have several unique tax compliance and planning challenges. Determining the character of the partnership’s income regarding the foreign partner is a critical first step for tax professionals advising partnerships with non-U.S. partners.

The Service requires U.S. partnerships to collect and report certain information regarding their non-U.S. partners. Importantly, the recent overlay of FATCA withholding requirements often means partnerships and other business entities must make two different determinations of whether withholding is required.

U.S. tax law provides several different withholding requirements for foreign partners, depending on the type of income the partnership receives and the manner in which the partnership conducts its activities.

For partnerships engaged in a trade or business, their income typically will be deemed “effectively-connected income,” which has significantly different tax results with respect to both withholding consequences and tax rates than income that is not generated from being engaged in a trade or business.

Partnership tax advisers also must understand the affects of treaties both on the treatment of a partnership and its partners, as they may reduce or eliminate withholding requirements and income taxes on certain types of income. Having a basic understanding of foreign partnerships is key to providing the appropriate advice to U.S. partners, as using a foreign partnership may be the most advantageous way to handle the myriad issues that can arise.

Listen as our experienced panel provides a comprehensive and practical guide to the tax planning and reporting issues specific to partnerships with foreign partners.

Outline

  1. Income taxation of partnerships with foreign partners
  2. Blocker corporations and foreign partnerships
  3. Partnership Chapter 3 Withholding & Reporting
  4. Partnership Chapter 4 (FATCA) Withholding & Reporting
  5. Filing requirements

Benefits

The panel will discuss these and other important issues:

  • Documentation partnerships must obtain from foreign partners and associated reporting to the IRS
  • Withholding requirements for effectively-connected income for foreign partners
  • Withholding requirements for FDAP, FIRPTA, and other non-business partnership income
  • Use of blocker corporations and other intermediate entities
  • Impact of treaty positions on income taxes and withholding
  • Filing requirements

Learning Objectives

After completing this course, you will be able to:

  • Determine whether withholding is required and the proper withholding for effectively connected income (EIC)
  • Ascertain the various reporting requirements for U.S. partnerships with foreign partners
  • Distinguish FDAP and FIRPTA income
  • Establish the impact of treaties and intergovernmental agreements on withholding and reporting requirements
  • Verify that the all withholding and reporting requirements, including FATCA requirements, are fulfilled

Faculty

Alfred H. Bae
Ernst & Young, Houston

 

Rita M. Ryan
Vacovec Mayotte & Singer, Newton, Mass.

Ms. Ryan practices in the areas of international and domestic taxation, estate planning, and tax controversy. Prior to joining the firm, she was with PricewaterhouseCooper’s National Tax Services, Exempt Organization Tax Services group. While at PwC, she provided specialized tax consulting and compliance services to non-profit organizations including higher education institutes, foundations, and health care systems. Prior to her tenure at PwC, she served as an Appeals Officer with the Massachusetts Department of Revenue, Office of Appeals, where she heard and issued letters of determination with regard to corporate, individual, and estate tax matters.

Kenneth J. Vacovec, Founding Partner
Vacovec Mayotte & Singer, Newton, Mass.

Mr. Vacovec practices in all areas of tax law including tax planning for businesses and individuals, estate planning, representation before the IRS and state tax authorities, international tax planning for individuals and businesses, international estate planning, and tax compliance. He has given many presentations on divorce tax issues.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $147.00

Live Webinar & CPE Processing $182.00


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing partnership and other complex tax forms, supervising other preparers/accountants. Specific knowledge and understanding of partnership structure, domestic and foreign partnerships, withholding and reporting requirements, and effectively connected income (EIC); familiarity with FDAP and FIRPTA income, FATCA reporting, and treaties and intergovernmental agreements potential impact on withholding requirements.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $147.00
Available 48 hours after the live event

How does this work?

Recorded Audio Download (MP3) $147.00
Available 24 hours after the live event

How does this work?

DVD (Slide Presentation with Audio) $147.00 plus $9.45 S&H
Available ten business days after the live event

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Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $194.00

Recorded Webinar Download Only $47.00 with Registration/Webinar Combo

Live Webinar & Audio Download $194.00

Recorded Audio Download (MP3) Only $47.00 with Registration/MP3 Combo

Live Webinar & DVD $194.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $47.00 with Registration/DVD Combo


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Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

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EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

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Customer Reviews

I liked the concentration on specific issues and examples.

Edita Rimalovsky

Komisar Brady & Co.

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

I loved the tools and handouts. Every CPE class should offer these kind of tools.

Jackie Meyer

Sample and Bailey

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

Larry Bruck

WISS & Company

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

Matt Bristow

Cover & Rossiter

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